The goal of the radioactive material (RAM) security rules is to restrict access to and prevent unauthorized use or removal of RAM. RAM security is the responsibility of all individuals who work in any radiation use area as a part of their employment. Such personnel include radiation workers, non-radiation workers, or others who frequent the radiation use lab, such as University support personnel.
General Security Requirements
Security of radioactive material that is not specifically exempted by these rules or by Committee approval, whether in sealed or unsealed form, must be accomplished by at least one of the following methods:
- Keeping radioactive material under the constant “line of sight” surveillance by a radiation worker
- A radiation worker providing line of sight surveillance of RAM inventory must belong to the Approval to which the RAM belongs
- Locking the RAM use or storage area/laboratory
- Placing RAM in locked storage, such as a cabinet or refrigerator, with an installed lock or external lock and hasp within an approved RAM use or storage area/laboratory
Physical security must be complemented by challenging unauthorized entry into the lab. Visitors must be questioned as to their purpose for being in a radiation lab.
Increased Security Requirements
In addition to enacting one of the general security requirement methods listed above, the following RAM must be additionally secured in locked storage, such as a cabinet or refrigerator with an installed lock or external lock and hasp.
- All unsealed RAM belonging to an Approval that is authorized for unsealed radioactive material possession that exceeds 200 mCi of H-3 or a total of 50 mCi of all other radionuclides combined..
- All sealed sources not specifically described in the Exceptions section below.
Exceptions
Certain radioactive materials may be approved by Research Laboratory & Safety Services (RLSS) to require little or no security or control. Normal labeling and posting of rooms, areas, and equipment usually offers sufficient hazard communication for these types of radioactive materials. These materials include:
- Naturally occurring or depleted radioactive material (uranium and thorium compounds)
- Quantities of material exempt from licensing (licensing status is determined by the RLSS prior to ordering)
- Properly labeled RAM use equipment, such as pipettes, sinks, glassware, absorbents, tongs, etc.
- Generally Licensed material and items exempt from licensing (e.g., tritium exit signs, commercial smoke detectors, liquid scintillation counter internal and external check sources, and anti-static sources in balances)
- Sealed sources mounted in stationary equipment. Security requirements for these sources must be specifically exempted by RLSS
- Check sources attached to portable survey instruments
- Properly labeled radioactive material, to include waste, that when summed for any designated RAM use area, from all approvals, is not in excess of 40 μCi. Typical waste and material in this category include analytical samples, dry waste, cell and tissue cultures, autoradiography and electrophoresis plates, animal related waste, as well as liquid samples or wastes such as radioactive scintillation vials or chromatography cocktails.
- Liquid RAM must either be placed in secondary containment or upon suitable absorbents to limit the spread of contamination.
Security exemptions other than those listed above must be granted by the appropriate radiation safety committee. RLSS must be notified prior to ordering any radioactive material to determine the licensing status of the material and associated security requirements.
Facilities and Equipment Management by University Employees or Outside Contractors
University of Arizona Facilities Management (FM) personnel are trained by Research Laboratory & Safety Services to report abnormal conditions in radioactive material labs. Although recommended, FM personnel are not required to be accompanied when working in a radioactive materials lab.
Visitors and outside contractors shall be under constant supervision by a radiation worker when in radiation use areas. Such personnel do not need to be supervised if all RAM has been secured and if all RAM work areas are found to be free of contamination via a comprehensive, documented survey.
Loss or Theft of Radioactive Material
Any known or suspected loss or theft of radioactive material must be reported immediately to Research Laboratory & Safety Services (RLSS). Outside of normal business hours, RLSS can be reached through the University of Arizona Police Department.
Enforcement
RLSS staff members shall take every opportunity to verify compliance with these RAM security rules. Rooms found unoccupied with unsecured material will be in violation of the RAM security rules.
Willful violation or repeated violation of the security rules will be reported to the appropriate radiation safety committee and may result in suspension or revocation of approval to possess and use radioactive materials.
Frequently Asked Questions
Q: I store samples in a cold room. Should that cold room be locked?
Does the total amount of unsecured radioactive material and/or waste activity in the cold room exceed 40μCi?
- If yes, or if you are unsure, the radioactive material and/or waste in the cold room must be secured via one of the security methods listed in the General Security Requirements section, above.
- If no, the radioactive material and/or waste in the cold room is exempt from the security requirements.
Q: I intend to store 10 μCi of RAM in a cold room that is shared with other researchers. How do I know if my added activity causes the amount of RAM in that room to exceed 40μCi?
Do not assume that you are solely storing RAM in that cold room. Your RAM must be secured via one of the security methods listed in General Security Requirements, above, until you definitively determine the total amount of RAM in the room.
Q: I intend to count 200 liquid scintillation vial samples in a liquid scintillation counter (LSC) located in a common equipment room. These samples contain on average 0.21 μCi per vial (total 42 μCi). How do I communicate to others who use the common equipment room that the limit of 40μCi has been exceeded?
Because you are planning upon counting over 40μCi of samples, your samples must be secured using one of the security methods listed in General Security Requirements, above. Therefore, you must either remain with the samples to provide surveillance, lock the room, or lock the sample vials inside the LSC.
Q: If there is no radioactive material in a RAM lab, must the door be locked?
The door does not need to be locked if there is no radioactive material (including waste) to secure.
Q: Can an area within a designated RAM laboratory be locked for security purposes instead of the entire laboratory?
In some circumstances, the area or suite in which the material is used or stored can be secured rather than the entire room in which the material is used or stored. Contact Research Laboratory & Safety Services if you require help in determining such situations.
Q: If I’m in an office within the lab, can I leave the hallway door to the lab unlocked if I remain in the office and the office door is open?
Does the total amount of unsecured radioactive material and/or waste activity in the lab exceed 40μCi?
- If yes, or if you are unsure, the radioactive material and/or waste in the lab must be secured via one of the security methods listed in the General Security Requirements, above.
- If no, the radioactive material and/or waste in the lab is exempt from security requirements.
Q: Do I have to secure a common equipment room that contains a liquid scintillation counter (LSC)?
Does the total amount of unsecured radioactive material and/or waste activity in the equipment room exceed 40μCi?
- If yes, or if you are unsure, the radioactive material and/or waste in the equipment room must be secured via one of the security methods listed in General Security Requirements, above.
- If no, the radioactive material and/or waste in the equipment room is exempt from the general security requirements. The calibration vials shipped with the LSC are exempt from the security requirements.
Q: How do I ensure that personnel with unrestricted access to RAM use/storage areas are aware of the security requirements?
Radioactive material Approval Holders are required to provide a non-radiation worker safety orientation to all personnel who will not use radioactive material but require unrestricted access to RAM use or storage areas. This is accomplished by providing a brief laboratory orientation that includes the location of radioactive material storage and use areas as well as security and emergency response requirements.
Q: Our lab has several open entrances. One of those entrances leads to an adjacent lab. Must that entrance be secured or the radioactive material and waste in the lab remain under constant surveillance to be considered secure?
Does the total amount of unsecured radioactive material and/or waste activity in your lab exceed 40μCi?
- If yes, or if you are unsure, the radioactive material and waste in the lab must be secured via one of the security methods listed in General Security Requirements, above.
- If no, the radioactive material and waste in the lab is exempt from general security requirements.
Q: If all my useful radioactive material is securely stored in locked cabinets, can I leave my lab unsecured if only my waste is not secured?
Does the total amount of unsecured radioactive waste activity in your lab exceed 40μCi?
- If yes, or if you are unsure, the radioactive waste in the lab must be secured via one of the security methods listed in General Security Requirements, above.
- If no, the radioactive waste in the lab is exempt from security requirements.
Q: How do I know if my radioactive material is exempt from licensing?
Licensing status of radioactive material is determined prior to or upon arrival at the University of Arizona. All radioactive material must be received by or routed through Research Laboratory & Safety Services (RLSS) unless a written exemption has been granted by RLSS. If you have radioactive material and are unsure of its licensing status, please contact RLSS.
Q: May I secure any RAM outside of a designated RAM use/storage lab, such as a locked freezer?
No. It is no longer acceptable to store RAM stock, samples and waste in a locked cabinet, container or freezer that is located in an uncontrolled area (e.g., hallways).