Radiation Safety Office

SECTION VI

RADIATION SAFETY OFFICE POLICIES AND PROGRAMS

A. LABORATORY RULES AND PROCEDURES

The purpose of these rules and procedures is to provide a safe working environment for laboratory personnel, to ensure public safety, and to avoid contamination of equipment and facilities.

1. Radiation Laboratories

Radioactive materials may only be used and stored in specifically designated and approved areas. These "Radiation laboratories" are considered to be restricted areas, where access is controlled in order to protect individuals from exposure to radiation and radioactive materials. They will have a "Caution Radioactive Materials" label on the door or entrance area.

All equipment which is suspected to have come in contact with loose radioactive material (refrigerators, freezers, water baths, centrifuges, etc.), should be considered potentially contaminated and must be monitored for contamination by RSO personnel before being removed from the laboratory for repair, modification, calibration, storage, or use elsewhere.

Custodial personnel should only clean areas designated by the Authorized User. The users or their qualified laboratory personnel shall be responsible for the rest of the housecleaning. The Authorized User is responsible for ensuring that housekeeping personnel do not come in contact with radioactive contamination.

When the use or storage of a radioactive material in a facility is terminated, the RSO should be notified. Radiation Safety personnel will carry out a final survey of the laboratory before releasing the area for unrestricted use.

Eating, drinking, smoking, storage/preparation of food, and application of cosmetics are not permitted in radiation laboratories. This policy is not unique to the University of Pittsburgh. It is designed to minimize the risks of ingesting potentially harmful agents into the body.

We interpret the presence of coffee mugs, soft drink containers, food in refrigerators or cold rooms, coffee makers, and some microwave ovens as evidence that eating and drinking may be occurring in an area. Therefore, the Radiation Safety Office staff has been instructed to confiscate and dispose of any such materials found in a designated radiation laboratory, regardless of value.

B. SECURITY OF RADIOACTIVE MATERIALS

Background: Regulations pertaining to the security of radioactive materials require that "The licensee shall secure from unauthorized removal or access licensed materials that are stored in controlled or unrestricted areas," and that "the licensee shall control and maintain constant surveillance of licensed material that is in a controlled or unrestricted area and that is not in storage."

Policy: Radioactive materials are to be stored in a manner that will minimize the risk of breakage, leakage or theft. The use and storage of radioactive materials must either be under the constant surveillance and immediate control of a radiation worker or secured from unauthorized removal and access. These requirements are applicable to stock solutions, sealed sources, materials in process and radioactive waste.

Procedure: In accordance with the above policy the following shall be implemented:

RADIOACTIVE MATERIALS MUST BE USED AND/OR STORED IN POSTED ROOMS LISTED ON THE AUTHORIZED USER'S APPLICATION.

RADIOISOTOPE LABORATORIES ARE TO BE LOCKED WHEN UNOCCUPIED IF THERE ARE UNSECURED SOURCES OF RADIOACTIVE MATERIAL.

Material may be secured in a locked container such as a cabinet, refrigerator, shield, hood or storage box.

ANY INDIVIDUAL WHO IS UNKNOWN TO LABORATORY OCCUPANTS OR WHO IS UNFAMILIAR WITH THE WORK PRACTICES IN YOUR LABORATORY SHOULD BE "CHALLENGED" UPON ENTRY INTO AREAS IN WHICH MATERIALS ARE UNSECURED.

Exemptions: Small quantities of materials (liquid scintillation vials, gamma counting samples, etc.) in the process of being assayed in nuclear counting laboratories, exclusively used for that purpose. These materials are not exempt from proper handling and waste disposal procedures.

C. ORDERING AND RECEIPT OF RADIOACTIVE MATERIAL

All orders or requests for radioactive material must be approved by the Radiation Safety Office. All purchase requisitions for radioactive material must be submitted to the Radiation Safety Office for approval before going to the Purchasing Department. The requisition must clearly state:

1. Radionuclide

2. Compound or Catalog Number

3. Activity in microcuries or millicuries

4. Name of Authorized User ordering the material

The Radiation Safety Office must be notified in writing prior to receipt of items which do not require a purchase requisition such as evaluation products, free samples, or radioactive materials from other research institutions.

With the exception of certain radioactive material for clinical or human use, all packages containing radioactive material must be received through the Radiation Safety Office, G-7 Parran Hall, and surveyed for contamination before being delivered to the User's laboratory. If significant contamination is found, or if there is a discrepancy between the material in the package and what is stated on the purchase request, the User will be notified. Special handling instructions or requirements associated with the use of the radioactive material will be noted on the package.

D. PACKAGE OPENING PROCEDURE

Packages of radioactive materials will be monitored in accordance with requirements specified in 10 CFR 20 and 25 PA Code 219. Special handling instructions or precautions will be provided, when needed, for packages of radioactive material which are received at the Radiation Safety Office, before they are delivered to the User's laboratory.

All packages of radioactive material, exclusive of where or by whom they are received, will be subject to the following safe opening procedure:

PROCEDURE FOR SAFELY OPENING PACKAGES CONTAINING

RADIOACTIVE MATERIAL

1. Disposable gloves should be worn in order to prevent potential hand contamination.

2. Visually inspect the package for any sign of damage; e.g., wet or crushed. If damage is noted, notify the Radiation Safety Office.

3. For volatile material, place the package in a vented fume hood.

4. Open the inner packaging and verify that the contents agree with the packing slip.

5. Check the integrity of the final source container. Look for broken seals or vials, loss of liquid, or discoloration of the packing material. If there is reason to suspect contamination, perform a wipe survey to determine if there is removable radioactivity. Take precautions against the potential spread of contamination.

6. If anything in steps 5 and 6 is other than expected, stop further handling and notify the Radiation Safety Office.

7. Remove or obliterate any radiation labels from packaging materials before discarding in the regular trash. If contaminated, treat this material as radioactive waste.

E. TRANSFER OF RADIOACTIVE MATERIALS TO OTHERS

Ordering and receipt of radioactive materials is limited to those researchers who have received authorization from the University Radiation Safety Committee. Radioactive material is received under the University of Pittsburgh’s NRC or Pennsylvania licenses and may only be used in authorized University related facilities.

Transfers within University related facilities:

Transfer of radioactive material to other researchers is allowed, but only when the following two steps are taken:

1. Verify that the receiver is authorized to possess the isotope and

2. file a written notification of the transfer with the Radiation Safety Office.

RSO form "Internal Radioisotope Transfer Record " should be completed and submitted to G-7 Parran Hall. This form is available by calling the Radiation Safety Office at 624-2728. It is also available on the INTERNET at the Radiation Safety Office home page located at "http://www.radsafe.pitt.edu".

Transfers outside the University:

Radioactive material may only be transferred to individuals at other institutions by the Radiation Safety Office. Contact the Radiation Safety Office for assistance. Regulations require that the University have a written confirmation that the receiving institution is licensed for the material. Most institutions require, as we do, that all incoming material is delivered first to the Radiation Safety Office. U.S. Department of Transportation packaging requirements must be adhered to as well as the limitations imposed by the carriers such as UPS or FedEx. Improper shipments are subject to fines and legal action.

F. TRANSPORTATION OF RADIOACTIVE MATERIALS WITHIN THE UNIVERSITY COMPLEX UTILIZING PUBLIC PLACES

Radioactive materials (waste, stock vials or experiments in progress) are occasionally moved between laboratories on different floors or between buildings. Public hallways, elevators, stairwells and sidewalks are utilized. Every effort must be taken to minimize public exposures and prevent contamination.

Material must be in the possession of a trained radiation worker at all times. It may be hand carried or moved on a cart, but not transported in a vehicle. It is not acceptable to convey a radioactive package on a public transportation vehicle such as a campus van or public bus. If transport by vehicle is necessary, please consult with the Radiation Safety Office prior to transport.

The material should not be carried in an open state, but should be contained in a closed package or overpack. The criterion is that the radioactive contents should not spill out of the container if it is dropped. As appropriate, consideration should be made for absorbent material and shielding.

Care should be taken when packaging the radioactive material so that the outside of the container and subsequently the carrier does not become contaminated.

Waste bags should be taped or tied closed, with a proper label attached.

Gloves, if worn, should be a clean pair so that contamination is not transferred to doorknobs, elevator buttons, etc..

G. LABORATORY SURVEYS

Laboratory personnel are required to perform and document laboratory surveys in accordance with the following program:

Documented Radiation Laboratory Survey Program

Purpose

The purpose of a survey is to identify sources of radiation contamination and exposure. All laboratory personnel should be aware of these sources of exposure. Corrective action should be taken as necessary to insure a safe work environment. Documentation of radiation surveys must be retained. This policy does not eliminate the need for daily checks of the work place and routine surveys of personnel.

Frequency of Surveys

Surveys must be performed weekly in all laboratories where radioactive material was in use during that week.

"Use" means removal from stock vial for experiment and/or processing radio-labeled compounds or probes in open containers, waste handling or discharge to sink. Receipt and placement into storage of stock vials does not constitute use. Analysis of samples in liquid scintillation or gamma counters is not considered use of radioactive materials.

"Laboratories" do not include darkrooms, freezer/refrigerator rooms and counting equipment rooms. Common equipment rooms, and cold/warm rooms are considered to be laboratories; however, they are exempt from surveys by laboratory personnel if there is no use of unsealed radioactive material. Detection of contamination by the Radiation Safety Office will revoke the exempt status in these rooms.

Survey procedure

Meter surveys are required for all laboratories except those exclusively using C-14, H-3, S-35, Ca-45 or other weak beta emitting (<200 Kev) radionuclides.

Perform a radiation survey with an operational portable survey instrument. Survey with detector end caps and beta shields removed. Select the most sensitive (lowest) range of the instrument. Turn the speaker on. Survey all work and storage areas, waste containers, accessible surfaces and Rad labeled equipment. Record (in CPM) the background reading and all readings above background on the report form.

Smear Surveys are required for all laboratories except those exclusively using micro spheres.

Perform a contamination survey, taking smears representative of both Rad work and clean areas. A one inch dry paper filter or a cotton swab is a good smear. For uniformity of results, smear an area of 100 cm² (four inch square). All areas with radiation levels above background should be smeared. Pay particular attention to areas which may have been contaminated, such as switches, handles, etc. Be careful to not inadvertently contaminate the smears or transfer contamination to a clean surface in the process.

Count smears with an appropriate instrument. Low energy beta emitters (C-14, H-3, S-35, Ca-45) must be counted in a liquid scintillation counter. Medium and high energy beta emitters or beta/gamma emitters may be counted with a thin window "GM" survey instrument. Smear analysis should be made in a low background environment. Photon emitters such as I-125 and Cr-51 should be counted in a gamma counter or with a thin crystal NaI detector.

Using the counting efficiency for the instrument selected (see Table 1), calculate dpm/smear. Record background and net (gross minus background) dpm on the survey report. Also record the counting instrument used.

TABLE 1 Average Counting Efficiency for Standard Instruments^1,2 (Detector window 1 cm above source)
Betas	Scintillation counter	Pancake GM	End Window GM
³H, ⁵⁵Fe, ⁶³Ni	50 %	NOT APPLICABLE	NOT APPLICABLE
¹⁴C, ³⁵S	90 %	2 %	1 %
³³P, ⁴⁵Ca	90 %	15 %	10 %
³²P, ³⁶Cl, ⁸⁶Rb	100 %	35 %	20 %
Photons		NaI (Thin)	Gamma counter
¹⁰⁹Cd, ¹²⁵I		45 %	60 %
²²Na, ⁵¹Cr, ⁶⁵Zn, ¹¹¹In, ¹³¹I, ⁴⁶Sc, ⁹⁵Nb, ¹⁰³Ru, ¹¹³Sn,¹⁴¹Ce		30 %	Unit specific

^{1
Specific efficiency data may be determined for the specific instruments
and nuclides in use in a particular laboratory. That information may be
used on survey records.

^{2
Efficiency may be reduced if the emission rate from a particular
radionuclide is less than 100 %.}}

Action Levels

Evaluate contamination removed and take action per Table 2:

TABLE 2 Action Levels for Removable Surface Contamination in Radiation Laboratories
'Clean areas' - bench tops, floors, freezers, refrigerators, desks, etc
<220 dpm	Acceptable level
> 220 dpm but < 2200 dpm	Decontamination recommended
> 2200 dpm	Decontamination required
Radiation labeled equipment--rad sinks, centrifuges, fume hoods, waste cans, etc
< 2200 dpm	Acceptable level
> 2200 dpm but < 22,000 dpm	Decontamination recommended
> 22,000 dpm	Decontamination required

Documentation and record keeping

The survey form used to document laboratory surveys must contain the following information AT A MINIMUM:

Location, date of survey, name of individual performing the survey, isotopes in use, survey instrument(s) used, room layout drawing, counting equipment used, efficiency of counting equipment, results of surveys, notation as to corrective actions taken.

The survey forms may be patterned after the Radiation Safety Office laboratory survey form. An acceptable generic form is included in Appendix A. Complete all information requested on the form. Sign and date the form.

For weeks when no use of radioactive materials occurs, an entry should be made on the master calendar sheet that no survey is required that week.

File the completed forms in a file folder or loose leaf binder. The survey reports are subject to review by RSO and NRC personnel.

Survey reports must be retained for two years.

Common use or shared laboratories

For laboratories which are used by multiple Authorized Users, the responsibility for performing the weekly survey should be given to a mutually agreed upon individual.

Availability of Training

The Radiation Safety Office will conduct training on how to perform proper surveys for any laboratory that requests it.

Laboratories authorized for the use of radioactive materials will be surveyed and audited periodically by Radiation Safety personnel to assure radiologically safe working conditions.

H. USE OF RADIOACTIVE MATERIALS IN ANIMALS

The use of radioactive material in animals requires protocol approval from the IACUC and observance of Radiation Safety Office Guidelines.

If the study is an acute study, it may be allowed to be performed in the research laboratory. It is the responsibility of the Authorized User to make certain his or her associates and employees understand and exercise the necessary safety precautions, handling procedures, clean up responsibilities, and waste disposal methods.

If the study requires use of radiolabeled animals in institutionally managed facilities, then the responsibility for animal care may be shared between the investigator and animal facility personnel. This division of responsibility must be developed co-operatively, before the study begins.

The following are some guidelines for the use of radioactive materials in animals:

1. The administration of radioactive materials to/into animals and the subsequent dissection of those animals should be performed in trays lined with absorbent padding.

2. Cages that house animals containing radioactive materials should be labeled with the name of the radionuclide, activity per animal, date of administration, and Authorized User's name.

3. Volatile and readily dispersible radioactive material should be administered in a fume hood. Subsequent work with the animal may also be best handled within the fume hood.

4. Animal carcasses and tissues containing radioactive material should be placed in a yellow plastic bag. Do not include any other materials such as pads, tubing, needles, instruments, etc. with the carcass. The bags can then be taken to a radioactive waste storage area during scheduled hours or by special arrangement. Radioactive animals and tissues should be kept refrigerated or frozen before delivery to Radiation Safety personnel.

5. Animal excreta may be disposed of through the sanitary sewer in accordance with the applicable limits for liquid waste (30 uCi/day).

6. Any material returned to the institutional animal care facility, such as cages, must be decontaminated prior to return.

I. PERSONNEL RADIATION MONITORING REQUIREMENTS

External Monitoring

The following table summarizes the various types of radiation work performed under the University of Pittsburgh licenses. For each type of work, the type of monitoring (if any) is indicated.For radioisotope users, dosimetry is required for the handling of material in quantities equal to or greater than the indicated activity. For example, a radiation worker handling 5 mCi or more of Cr-51 is required to wear both ring and whole body dosimeters; however, a worker handling less than 5 mCi is not required to wear dosimetry. It is also required that all workers who have been issued dosimetry wear it at all times when handling isotopes, regardless of the activity level.

Type of Radiation Work	Activity level for Ring Dosimeter	Activity level for Whole Body Dosimeter
1) Radioisotopes (For isotopes not listed, contact RSO for guidance) Photon Emitters
Group 1 - Na-22, Sc-46, Fe-59, Co-60, Sr-85, Nb-95	1 mCi	5 mCi
Group 2 - Cr-51, Co-57, I-125, I-131, Ce-141, In-111	5 mCi	5 mCi
Beta Emitters
Emax > 500 Kev P-32, Cl-36	1 mCi	5 mCi
Emax < 500 Kev H-3, C-14, S-35, Ca-45, Ni-63, P-33	Not required	Not required
2) Sealed sources or gamma irradiators	AR	AR
3) Analytical x-ray equipment	yes	AR
4) Clinical or research x-ray equipment	AR	yes
5) Particle accelerator	AR	yes

AR = As required by RSO

Internal Monitoring

Bioassays will be conducted for personnel handling or processing unsealed sources of radioactive material in excess of the amounts stated in the NRC license documentation. In addition, bioassays will be conducted when deemed necessary, such as part of investigations into accidental releases. Individuals involved in uses which require bioassay will be informed of the specific requirements by the RSO.

J. AIR SAMPLING AND POST-EXPERIMENTAL PROCEDURE SURVEYSAir monitoring is required to be performed during experiments involving volatile radioactive compounds in quantities requiring bioassay in order to assure that concentrations of radioactivity in workplace air or released air do not present an exposure hazard or exceed legal limits. Arrangements for air sampling must be made with the RSO.Post procedure contamination surveys are required following experiments utilizing quantities of radioactive materials which require a bioassay in order to assure that contamination has not been spread over the work area. Surveys should be documented and filed with regular laboratory surveys for review by RSO staff.

The following table summarizes the conditions under which air monitoring and/or post-experimental procedure surveys are required:

TABLE 11: CRITERIA FOR AIR MONITORING AND POST PROCEDURE SURVEYS
Radioactive material use	Air monitoring	Post-procedure survey
Labeling procedureusing > 1 mCi of a radio iodine compound	X	X
Procedure using > 2.5 ALI of any volatile radionuclide	X	X
Procedure using > 25 ALI of a non-volatile radionuclide compound		X

ALI values are listed in Appendix C.

K. SCINTILLATION COUNTING

Only biodegradable or environmentally safe scintillation cocktails may be used, unless a special exemption is granted by the Radiation Safety Office. A list of acceptable cocktails is available from the RSO.

Plastic vials must be used unless a special exemption is granted by the Radiation Safety Office.

L. PREGNANT RADIATION WORKER POLICY:

Limits On Occupational Radiation Exposure to Employees Who Are Pregnant or Breast Feeding

Background: Exposure of the embryo/fetus to ionizing radiation carries a risk of causing certain adverse health effects such as cancer and developmental abnormalities. Accordingly, the National Council on Radiation Protection and Measurement (NCRP) has recommended that the total dose equivalent to the embryo/fetus from occupational exposure of the expectant mother not exceed 500 mRem (NCRP Report No. 53), and that once the pregnancy is known, exposure of the embryo/fetus not exceed 50 mRem in any month (NCRP No. 91). The Nuclear Regulatory Commission (NRC) requires (in revised 10 CFR 20.1208) that the dose to an embryo/fetus during the entire pregnancy, due to occupational exposure of a declared pregnant woman, not exceed 500 mRem, and that substantial variations in a uniform monthly exposure rate to satisfy this limit be avoided. The dose to the embryo/fetus is taken as the sum of the external deep dose equivalent to the pregnant woman and the dose from radionuclides incorporated in the embryo/fetus and pregnant woman.In support of the NCRP recommendations and NRC regulations, the University of Pittsburgh's Radiation Safety Committee has instituted the following policy and guidelines for occupational radiation exposure of employees who are pregnant or breast-feeding.Policy: The dose to an embryo/fetus during the entire pregnancy, due to occupational exposure of a declared pregnant woman, will be limited to 500 mRem. Substantial variations in a uniform monthly exposure rate should be avoided. Limits of exposure to the general population will be applied to a nursing infant. Work restrictions may be required in order to meet the intent of this policy. Procedure: A radiation worker who becomes pregnant should notify her department head or supervisor and the Radiation Safety Office (RSO) as early as possible. If the employee chooses not to declare the pregnancy to the Radiation Safety Office, additional controls and monitoring for her radiation exposure cannot be implemented. Declarations of pregnancy must be made in writing and submitted to the Radiation Safety Office. Upon notification of pregnancy, the RSO will provide instruction on the risks of radiation exposure to the embryo/fetus and review NRC Regulatory Guide 8.13 "Instruction Concerning Prenatal Radiation Exposure". The RSO will also evaluate the employee's radiation work environment, past exposure history and potential for future exposure. Based on this information, the RSO may make recommendations or impose restrictions regarding the employee's duties involving occupational radiation exposure. This review and evaluation will be documented, signed by the employee, the employee's department head or supervisor, the Radiation Safety Officer, and be filed in the RSO The pregnant employee may continue working in those areas and job duties where it is unlikely that her external and internal radiation exposures will exceed the total and monthly limits to the embryo/fetus, with proper attention to safe radiation practices. A pregnant employee will be restricted from those areas and job duties where there is potential for a significant radiation dose to the embryo/fetus from either an external or internal exposure. Examples of these types of situations are, but not limited to: administration of radiopharmaceutical therapy or brachytherapy, caring for patients receiving radiopharmaceutical therapy or brachytherapy, and performing iodinations or working in a laboratory where radioiodine in a volatile form is being used Appropriate radiation monitoring will be provided if it is likely that the embryo/fetus might receive an external dose of more than 50 mRem during the entire pregnancy. Bioassay will be required to monitor internal exposures for workers handling unsealed sources of radioactive material, if it is likely that an intake of a radionuclide would exceed 1% of an Annual Limit on Intake (ALI) during the entire period of gestation. Records of the dose to the embryo/fetus will be maintained with the mother's radiation dose records If the total effective dose to the embryo/fetus of the declared pregnant woman exceeds 400 mRem, she will be restricted from any further work involving occupational radiation exposure for the remainder of the pregnancy An employee who is breast-feeding may be restricted from those areas and job duties where unsealed sources of volatile radioactive materials are used. Bioassay may be required to monitor internal exposures of nursing workers handling unsealed sources of radioactive material. Recommendations will be made, based on the bioassay results, to assure that the nursing infant does not receive a committed effective dose equivalent of more than 100 mRem.

The information contained in this policy, and a copy of the NRC Regulatory Guide 8.13, will be provided to all radiation workers at the time of their initial radiation safety training.

M. RADIOACTIVE WASTE DISPOSAL PROCEDURESRadioactive wastes are an unavoidable byproduct of any use of radioactive materials. Once produced these wastes must be disposed of in a manner which minimizes impacts on public health and safety. A wide variety of laws and regulations are in force at the federal, state and local level which dictate how wastes are to be packaged, processed or disposed. At the same time, these wastes must be disposed of in the most cost effective manner possible. The University of Pittsburgh remains responsible for all licensed radioactive materials until they have been properly processed, decayed or placed in a licensed permanent repository.

The following guidelines have been developed to facilitate safe and efficient processing of radioactive wastes generated by most users at the University. It is recognized that while these general procedures and waste classifications will cover most situations, there will be exceptions and special cases. Should any questions arise as to specific disposal procedures, the Radiation Safety Office should be consulted

1. WASTE MINIMIZATION

One of the most important steps to the safe handling and disposal of radioactive wastes is to minimize the amount and types of waste generated. This process begins with design of an experiment and includes how materials are ultimately used and ultimately disposed. In all cases the total activity of materials used in an experiment should be kept as allow as practical. The use of immunofluorescent, or stable isotope techniques in place of radiolabeled procedures are examples of total avoidance of radioactive waste production. The use of aqueous or "biodegradable" solvent systems in place of hazardous solvent systems eliminates the production of costly mixed wastes. The use of short-lived radionuclides reduces the volume of wastes which must ultimately be sent to a permanent waste facility. Finally where long-lived isotope use is unavoidable, a significant effort can be made to produce the smallest quantity of contaminated wastes practical.

2. WASTE DISPOSAL

With the exception of aqueous liquid wastes disposed to the sanitary sewer, all radioactive wastes must be disposed of by Radiation Safety Office personnel. It is the responsibility of the authorized user and individual laboratory personnel to properly package wastes and bring it to an approved rad waste handling site (see TABLE 12). The Radiation Safety Office will provide all routine packaging materials (bags, tags, jugs, absorbent..). Special materials such as sharps containers are to be provided by of the individual authorized user. All non-standard materials must be approved by the RSO prior to use.

3. WASTE STORAGE

All wastes should be stored in appropriate LABELED waste containers and SECURED to prevent inappropriate disposal. If temporary containers such as beakers or plastic bags are to be used in the immediate work area, they should be emptied at the end of each day unless they are labeled and appropriately secured. Wastes should be routinely removed from the laboratory to one of the waste processing or storage areas (see TABLE 12).

Solid wastes should be stored in rigid containers with lids, lined with a yellow plastic bag. Where appropriate these containers should be of such a construction to provide shielding from unnecessary radiation exposures. The radiation safety office recommends that these containers be of "step-top" design. These containers are to be provided by the individual authorized user. A list of acceptable containers is available from the Radiation Safety Office. Waste containers should be surveyed frequently for contamination. Contaminated containers should be disposed of or decontaminated.

Liquid wastes should be stored in appropriate containers to minimize the chance of spillage. Liquid wastes should be promptly solidified or where appropriate, disposed to the sanitary sewer. If bulk liquids are to be held for storage a secondary container of adequate volume to contain all spilled liquids should be used. All containers should be labeled as radioactive waste. If appropriate, they should be of such a construction to provide shielding from unnecessary radiation exposures. 4. LABELING WASTES FOR DISPOSAL:All wastes consigned to the Radiation Safety Office for disposal must be labeled with a radioactive waste tag. Labels are available from the Radiation Safety Office.

Each container of radioactive waste must have a properly completed radioactive waste tag affixed to it. All information must be legible, in indelible ink, and include:

M the isotope

M an accurate estimate of activity IN MILLICURIES M the name of the authorized user M the date the waste is prepared for disposal.

M the type of waste

5. SEGREGATION OF RADIOACTIVE WASTE

Segregation of wastes at the point of generation is an essential in the safe handling and disposal of radioactive wastes. Radioactive wastes within the University system can be broken down into six broad categories, each with specific disposal requirements:

Dry Solid Wastes:

Contaminated paper, plastic, and glass associated with radioactive materials work, residual solid radioactive materials, contaminated building debris etc..

Liquid Wastes:

Any non-hazardous liquid containing dissolved or suspended radioactive materials.

Scintillation Wastes:

Vial, plates or bulk liquid wastes and other materials containing solutions used in liquid scintillation counting.

Biological Wastes:

Animal carcasses, blood, tissue samples, food wastes, solid or liquid excreta or other organic material not rendered resistant to decomposition.

Mixed Wastes:

Any wastes, solid or liquid which possess inherent hazards in addition to being radioactive, including listed hazardous chemicals, infectious or biohazardous materials.

Sealed Sources:

Radioactive materials encapsulated, plated or otherwise incorporated into a solid support media used in association with an instrument or device.

In addition to segregation by waste class all wastes must also be segregated by isotope. Upon written application to the RSO, an exception to this rule may be granted, such as in the case of multiple label experiments.Whenever possible high activity wastes, such as stock vials, should not be mixed with regular dry wastes and should be packaged separately. This is necessary to facilitate shielding and minimize storage and/or disposal volumes.

6. GENERAL LABORATORY GUIDELINES

All wastes should be stored in a labeled storage container appropriate for the specific waste stream.Keep volumes as small as possible.Place ONLY radioactive materials in the radioactive waste containers - mixing non-radioactive waste and radioactive wastes results in unnecessary increases in disposal costs.

NEVER use dry waste containers for free liquids, scintillation vials, biological animal carcasses, or lead wastes.

Wastes containing hazardous, biological, pathogenic or infectious material must be treated to reduce these potential hazards to the maximum extent practicable prior to disposal.Wastes must not contain or be capable of generating gases, vapors, or fumes harmful to persons transporting, handling, or disposing of those wastes.Wastes must not be pyrophoric. Wastes capable of igniting spontaneously must be treated and rendered non-flammable prior to disposal."Sharps" , including but not limited to syringes, pasteur pipettes, razor blades, scalpels and broken glass, must be packaged in a specifically designed sharps container.Where possible, wastes containing low levels of ¹²⁵I should be limited to less than 10 microcuries per container.When animals are used with ¹⁴C and ³H, whenever possible, restrict concentrations to less than 0.05 μCi/gram of animal tissue.

7. SPECIFIC GUIDELINES

A. LIQUID WASTE

Any liquid, other than liquid scintillation fluids, containing dissolved or suspended radioactive materials constitutes liquid radioactive waste. Liquid wastes can be classified into three basic groups:

LOW LEVEL AQUEOUS/WATER SOLUBLE WASTES

Radioactive liquid wastes which are fully soluble or biologically dispersible in water may be discharged directly into the sanitary sewer system via a designated radiation sink drain. The permissible limit of disposal by this means is restricted to less than 100 microcuries per day of ³H, and 30 microcuries per day of all other nuclides combined, averaged over a week. Alpha emitting nuclides are not permitted to be disposed of by this means. Sinks must be appropriately designated and labeled (one sink per laboratory).

Taking care to minimize splashing, pour the liquid waste directly into the drain with the water turned off. This should be followed immediately by a water flush with copious quantities of water. All disposal must be recorded on a sink log noting the date, isotope activity and the initials of the person disposing of the material. If total activities greater than the weekly limits are generated contact the Radiation Safety Office for special disposal directions.

HIGH LEVEL AQUEOUS/WATER SOLUBLE WASTES:

Aqueous or water soluble wastes excluded from sink disposal due to their activity or other characteristics, such as alpha emitters, must be solidified or absorbed with an approved media. Plastic jugs containing approved solidification media are available through the Radiation Safety Office. Once treated, these wastes should be placed in yellow plastic bags and labeled with the authorized user's name, the isotope, the estimated activity and the date of closure. (Treated liquid wastes may be disposed of with higher level dry solid wastes). Never accumulate high level liquid wastes in the laboratory without appropriate containment and shielding.

NON-AQUEOUS WASTES (EPA - "MIXED WASTE")

Most non-aqueous liquid wastes are excluded from sink disposal due to their insolubility or other characteristics. They must be packaged in accordance with both NRC and EPA hazardous waste regulations. Specific disposal direction must be obtained from the Radiation Safety Office PRIOR to generating these types of waste.

B. DRY SOLID WASTE

Dry compatible radioactive wastes such as gloves, padding, paper, plastic and glass should be segregated according to isotope and placed into appropriate labeled waste containers lined with RSO approved yellow plastic bags. Whenever possible low level wastes such as paper wastes, gloves etc., should be kept separate from high level materials such as columns, gels and residual stock vials.

C. "SHARPS" WASTE

All broken glassware, needles, pipettes and other items which can penetrate the waste bags should be placed into a sharps container for disposal. These containers should then be placed into a yellow waste bag and appropriately closed and labeled.

D. LEAD WASTE

Lead containers must be packaged separately from normal solid wastes. As with all radioactive wastes, these bags must be labeled clearly with a radioactive waste tag. Empty containers should be bagged with the lids or caps detached. Vials of radioactive material MAY be left in the lead container to provide shielding for any residual activity. The remaining activity must be clearly marked on the waste tag. If large lead objects such as contaminated shielding bricks are involved, please contact the Radiation Safety Office for instructions.

E. LIQUID SCINTILLATION WASTE

Vials, tubes or other containers used with or containing solutions used for liquid scintillation counting constitute liquid scintillation wastes. If available, scintillation vials should be repacked into the original cardboard trays or cartons. The RSO will accept a complete carton of trays if it is taped closed and a completed waste tag applied. Smaller quantities of vials may be packed one or two "flats" per bag, closed and labeled. Mini vials and bulk tubes should be placed into a yellow plastic bag. An absorbent paper pad or several paper towels should be placed in the bottom of the bag to absorb minor leakage.

RESEARCHERS MUST USE PLASTIC SCINTILLATION VIALS AND NON-HAZARDOUS BIODEGRADABLE SCINTILLATION MEDIA, UNLESS OTHERWISE SPECIFICALLY AUTHORIZED BY THE RADIATION SAFETY OFFICE.SCINTILLATION WASTES ARE NOT TO BE DISPOSED OF BY POURING DOWN THE DRAIN.SPECIAL DISPOSAL ARRANGEMENTS MUST BE MADE FOR GLASS VIALS, BULK LIQUIDS AND TOLUENE/XYLENE BASED WASTES.

F. BIOLOGICAL WASTE

The carcasses of research animals used with radioactive materials and any solid or liquid radioactive waste containing significant quantities of tissue or excreta are classified as biological wastes. These wastes require special handling and packaging in order to meet disposal criteria. As such they MUST BE SEGREGATED from other waste streams and properly identified as

ANIMAL CARCASSES.

The remains of experimental animals, organ or tissues to which radioactive materials have been administered should be placed into yellow plastic bags properly labeled and frozen immediately. These wastes are then to be transferred directly to a designated storage freezer, or to the waste processing areas attended by Radiation Safety personnel.

When using ¹⁴C and ³H, whenever possible restrict concentrations to less than 0.05 μCi/gram of animal tissue. This facilitates disposal as De Minimis waste. The use of formaldehyde/formalin and other hazardous chemical agents must be restricted. These wastes constitute a mixed waste stream and are very difficult to dispose of. If these agents are to be used please contact the Radiation Safety Office for special packaging procedures. Blood, urine and other liquid biological wastes, not suitable for sanitary sewer disposal, must be adsorbed with an approved media or otherwise converted to solid form prior to disposal. These materials MAY NOT be disposed as regular dry solid or absorbed liquid waste.Ashed, freeze dried, or otherwise desiccated biological wastes may be disposed of as dry solid wastes only if liquids are excluded from the same package.UNDER NO CIRCUMSTANCES ARE CARCASSES TO BE PLACED IN RAD WASTE DRUMS, OR STORED AT ROOM TEMPERATURE !!

OTHER BIOLOGICAL WASTES

Materials associated with animal or tissue work containing significant biological material must be treated as biological waste. This category of waste includes any material which will decompose at room temperature to release gasses, vapors or fumes which may be hazardous to personnel transporting or otherwise handling these materials.

Revised 11/97

Appendix A
Table of Contents

Radiation Safety Office
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Revised February 14, 2006