Security of Radioisotopes
The U.S. Nuclear Regulatory Commission, in the wake of recent incidents
at other institutions, is closely scrutinizing the security
practices of radioactive material users at all licensed institutions.
As you know, the University and all of its users of radioactive materials
are required to comply with NRC regulations and policy. The NRC's current
policy requires that all radioactive material must be secured from unauthorized
use by remaining either under the constant surveillance of an authorized
person or locked away at all times. As applied to laboratories at Yale,
the NRC requirements include the following guidelines, which must be
followed:
Radioactive material must be secured from unauthorized use. If in an
unsecured use area (e.g., an unlocked laboratory), when not
in locked storage, the material must be maintained under "constant surveillance." This
means that an authorized person must at all times be in the laboratory
or surrounding area where he or she is in a position to monitor for unauthorized
persons entering the laboratory and to intervene upon observing someone
who could walk away with the material. This requirement applies to radioactive
material in waste and experiments in progress as well as to stock solutions.
There is no exempt quantity of material that does not require this level
of security.
Yale must make certain that unauthorized persons are not able to leave
the laboratories with radioactive material. Toward that end, the NRC expects
that unknown or unauthorized persons encountered in the laboratory will
be challenged as to their identity and intent. Persons without justification
for being in the laboratory are not allowed to remain unaccompanied in
the laboratory.
A posted laboratory containing any amount of unsecured radioactive material
must be locked at all times, except when an authorized person is present
in the laboratory or in an immediately surrounding area which permits continuous
monitoring of the entrance to the lab.
Yale
University is required to comply with the NRC policy as it is currently
interpreted. Failure to comply with these security regulations may put
your ordering privileges in jeopardy.
The following hypothetical examples illustrate the current NRC policy:
- The only laboratory member working on a weekend day is
in an area outside her posted lab, but where the entrance
to her lab is readily visible at all times. The lab contains
radioactive material in the radioactive waste container.
She remains aware of persons near the lab and challenges
any unauthorized person attempting to enter the lab. A Yale
Physical Plant worker, whom the laboratory member had called,
arrives to repair a light fixture. She allows him into the
lab. This complies with the NRC policy.
- A laboratory member is in the posted lab or surrounding
area. No other lab member is present. The laboratory contains
radioactive materials in experiments in progress on the bench
top in various parts of the lab. An unexpected visitor arrives
whom the laboratory member does not know. The laboratory
member asks the visitor who she is, and she tells him that
she needs to inspect the lab; he does not ask her for identification.
The laboratory member then allows the visitor to roam the
lab without monitoring her activities. This fails to comply
with NRC requirements.
- A posted laboratory is not actively using radioactive
material at the present time. The radioactive stock vial
in storage in the laboratory is in a locked box in the freezer.
There is no radioactive waste in the laboratory nor experiments
in progress. This meets NRC requirements because the radioactive
material is stored in a locked box.
Radiation Safety staff are available to help you understand
and maintain compliance with these regulations. Please do not
hesitate to call Radiation Safety Section personnel at 785-3550 if you
have questions. Thank you for your cooperation.
