2. Organization and Responsibility

The Chancellor is responsible for providing and enforcing a radiation safety program that protects user safety and complies with local, state, and federal regulations related to the use of ionizing radiation. The Chancellor delegates responsibility for the development, implementation, and enforcement of the radiation safety program to the committees, departments, and individuals described below. The Chancellor retains responsibility for signing the “Statement of Intent” to ensure funds will be available for decommissioning of radioactive material use locations.

The VCR plays a lead role in the UC Berkeley radiation safety program. The VCR appoints members of the RSC and its Chair, reviews reports provided by the RSC, and assists it in accomplishing its goals and mission.

The VCR reviews information on radiation and radiation safety policies, matters related to radiation safety, the status of the program, and problems that may require management’s attention when these are brought to his or her attention by the RSC, RSO or Director of EH&S.

The RSC is a body of faculty and other radiation experts appointed by the VCR to work with executive management and the Radiation Safety Officer (RSO) to establish policies and procedures for the use of ionizing radiation at UC Berkeley. In addition, the RSC maintains oversight over the program and provides periodic program status reports to the VCR. Oversight activities include the review and approval of radiation-use applications and the review of EH&S radiation safety and radioactive waste related operations.

The RSC ensures that campus executive management is adequately informed of its responsibilities on matters related to radiation safety, the status of the program, and problems that require management attention. Upon request, EH&S can provide a full description of the responsibilities of the RSC and the RSC bylaws.

EH&S implements the campus radiation safety program. EH&S ensures regulatory compliance and safety in the use of radiation and radioactive materials. The program includes audits of all authorizations for the use of radionuclides and Radiation Producing Machines (RPMs). Specific functions of EH&S includes, but is not limited to:

• Monitoring radiation exposure levels
• Investigating incidents involving ionizing radiation
• Consulting on safety matters
• Providing radiation-safety training and services
• Managing radioactive wastes

2.4.1. Executive Director, Environment, Health & Safety

The EH&S Executive Director is responsible for the overall management of the campus radiation safety program, in accordance with policy approved by the RSC and with the direction provided by senior campus administrators. The EH&S Executive Director serves on the RSC representing campus executive management.

2.4.2. Radiation Safety Officer (RSO)

The RSO has responsibility for overseeing the radiation safety program and for ensuring that radiation uses conform to UC Berkeley policies and applicable government regulations, including the UC Berkeley Radioactive Materials License. The RSO is a member of the RSC and is responsible for referring to the committee all matters requiring its review and approval. The RSO reports to the Executive Director of EH&S.

The RSO is empowered to halt any radioactive operations that pose an immediate health and safety danger to the public and/or workers. If the RSC Chair or a second member of the RSC is immediately available, the decision to stop work is coordinated with that person. If not, the RSO has the authority to act alone. The RSO and RSC Chair determine whether and when an emergency meeting of the RSC should be held.

Along with the RSO and RSC, Department Chairs and Unit Directors are responsible for reviewing and approving proposed uses of radioactive materials and RPMs within their jurisdictions. Their approval of the Radiation Use Authorization (RUA) signifies that the department will (1) provide the resources (including facilities and equipment) necessary to control hazards, and (2) comply with applicable campus and governmental standards and regulations.

The RUA Holder (RH) is the individual who has applied for and received authorization to use radioactive materials or RPMs. Each RH is responsible for:

• Ensuring that the laboratory (or other work area) is safe for use by personnel, including the radiation user(s);
• Ensuring that anyone permitted to work with or in proximity to sources of radiation or radioactive material has been added to the RUA and has received sufficient training to control and minimize exposure to themselves and others.
• The actions of radiation users listed on their RUA regardless of whether the RH is that person’s direct supervisor or not;
• Acquiring both radioactive materials and RPMs only from authorized vendors using authorized methods and ensuring that purchase requests for radioactive materials do not exceed the RUA inventory limits;
• Reading the RSM and maintaining compliance with the rules and precautions in the RSM and RUA;
• Keeping radiation exposures ALARA; and
• Informing the RSO of any unsafe conditions, radioactive spills or radiation incidents; and
• Posting of RUAs and other required signs/forms.

Proposed RHs must meet specific requirements. RHs must:

• Be employed by UC Berkeley or hold a faculty or research appointment from UC Berkeley;
• Possess a college degree or equivalent experience in the physical or biological sciences or engineering; and
• Have training and/or practical experience in all of the following:
  • The characteristics of ionizing radiation;
  • The manner in which radiation and radioactive materials are quantified and expressed;
  • How radiation dose is quantified and expressed;
  • Use of radiation-detection instrumentation; and
  • Biological hazards of exposures to the types, forms, and amounts of radiation sources to be used.

Users are persons who handle radioactive materials or use radiation producing machines (RPMs). Every user’s name must be listed in the personnel section of the Radiation Use Authorization (RUA). Users are responsible for their own safety and for the safety of those around them; specifically, they must:

• Follow procedures and protocols and know where the RSM can be found online and how to seek assistance from the RST;
• Read the RSM if they are a Lab Contact for the RUA;
• Ensure that training and safety equipment are adequate or check with the RH or RSO if there are any questions;
• Keep exposure to radiation as low as reasonably achievable (ALARA);
• Wear required personal protective equipment (PPE);
• Wear dosimetry and/or participate in the bioassay program if required;
• Inform the RH and/or RSO of any unsafe conditions;
• Keep personal items away from laboratory or use areas;
• Never eat, drink, smoke, or apply cosmetics in the laboratory;
• Place waste materials in appropriate, labeled containers;
• Label work areas, materials, and/or containers as required;
• Maintain appropriate security for radioactive materials and radiation producing machines;
• If contamination is suspected, check with a suitable survey meter or by means of an “area wipe” and decontaminate if necessary;
• Wash hands and check for contamination before leaving the laboratory, using a suitable survey meter; and
• Immediately report spills, personnel contamination, or other radiation safety emergencies to EH&S.

Minors between the ages of 14-18 years old who wish to work with radioactivity or radiation must be students in an enrolled class involving laboratories, or part of an approved or supervised tour, or have written consent of their parent or guardians and be under the direct supervision of a qualified adult. These restrictions apply to minors who are volunteers or summer interns. RHs must apply to the RSO for exceptions and exceptions must be documented in writing. Minors under the age of 14, including children of laboratory personnel, are not permitted in posted radiation use locations, except when participating in an approved and supervised tour. The RUA Holder must approve of a tour in their radiation use locations.

Ancillary personnel includes all workers (maintenance, researchers, interns, students, or administrative) who are assigned to perform work in areas listed on an RUA, but who are not working directly with radioactive materials or RPMs. The RH is responsible for ensuring that ancillary personnel receive radiation safety training commensurate with the potential radiological health protection risks in the controlled area. Ancillary Worker training is available on the EH&S radiation safety website for this purpose and this training must be documented.