How to stay in compliance with regulations

The U.S. Nuclear Regulatory Commission (NRC) issues licenses to users of byproduct materials in 21 states and the District of Columbia. The regulations governing the possession and use of these products are found in Title 10 of the Code of Federal Regulations (10 CFR) specifically Parts 19, 20, 30 and 35 for medical use of radionuclides. Some areas are clear and not likely to be misinterpreted but, there are some sections which may be interpreted in several ways. At our institution one of the reasons a Severity Level III violation was issued was due to the radiation safety officer's (RSO) interpretation of the regulation. A package containing 2 millicuries of iodine-125 was lost due to personnel not following established policies for the receipt of radioactive material. The RSO failed to notify NRC immediately because he did not think the criteria for immediate notification as stated in 10 CFR Part 20.2201 had been met. Part 20.2201 states that a licensee shall report by telephone immediately after its occurrence becomes known to the licensee any lost, stolen or missing licensed materials greater than specified quantities if it appears that an exposure could result to persons in unrestricted areas. It is important to keep abreast of the philosophy of the NRC and the areas that are of current interest to avoid violations. With the increase in the incidents of deliberate misuse of isotopes at medical or research facilities, NRC is wary of radioisotopes being tampered with and misused.