Enforcement Policy for Radiation Safety Infractions
Enforcement Policy for Radiation Safety InfractionsWhen a radiation safety infraction is identified by Radiation Safety staff during a laboratory inspection the infraction is noted on the inspection form. If the infraction poses an immediate risk to health, safety or the environment or a potentially imminent health hazard, appropriate action(s) will be taken immediately to control or eliminate the hazard/risk. These actions may include cessation of radioactive material activities, restricting access to the laboratory, locking out the power supply to radiation producing equipment, etc. Examples of imminent hazards/risks include, but are not limited to: a lost or missing radioactive source, extensive amounts of contamination, excessive exposures, and malfunctioning radiation producing equipment.
If no imminent hazard/risk is posed, the infraction will be discussed with the laboratory supervisor and/or other laboratory personnel, as appropriate, at the completion of the inspection. Formal notification of the inspection findings will be provided to the laboratory’s supervisor in the inspection summary sent by Radiation Safety staff.
Infraction Notification
Following each laboratory’s radiation safety inspection, an inspection summary will be sent to the laboratory’s supervisor. The inspection summary will indicate the infraction(s) found during the inspection and the associated enforcement classification and severity level(s), as well as recommendations regarding radiation use in the laboratory. The inspection summary will request the supervisor to remediate the infraction(s) and notify the RSO in writing, when applicable, of the corrective action(s) taken. Corrective actions taken at the time of the inspection will be noted on the inspection summary and no further action will generally be required. Supervisors will be notified during the inspection of situations found which require immediate action. If required, laboratory operations will be interrupted until the infraction(s) is corrected.
Types of Infractions
For the purpose of this enforcement policy, infractions are classified into two groups: violations and deviations. The infraction’s classification will be noted on the inspection form and on the supervisor’s inspection summary.
Severity Levels
Once the infraction has been classified as a deviation or violation, its level of severity is determined. The severity level will be assigned, at the discretion of Radiation Safety staff, based on the safety significance of the infraction. Six severity levels have been established in this Enforcement Policy, with Level I being the most serious, and Level VI being the least serious.
Enforcement Actions
The imposed enforcement action(s) will be determined based on the classification of infraction (i.e. violation or deviation) and its assigned level of severity. The Enforcement Table will be used as a guide for determining the appropriate enforcement action(s). The Enforcement Table provides typical actions which may be imposed, at the discretion of the Radiation Safety Officer and/or the Radiation Safety Committee, for cited infractions. This Table is not meant to be all inclusive and other actions may be imposed as necessary and/or appropriate.
Supervisors will be advised of the imposed enforcement action(s) in writing. Concerns, grievances, etc., regarding the inspection findings or imposed enforcement actions, will first be discussed with the Radiation Safety Officer. Unresolved issues will be submitted to and addressed by the Radiation Safety Committee.
Repetitive Infractions
A repetitive infraction is when the same infraction is noted during two consecutive inspections or when a similar infraction re-occurs because a previous infraction was not properly remediated. The enforcement action(s) for a repetitive infraction will be based on the next higher severity level than used for the previously cited infraction.