ALARA Policy

Policy Statement

Northwestern University is committed to the safe use of ionizing radiation in all aspects of its teaching and research mission.

It is the policy of Northwestern University to keep any and all exposures to (or releases of) radiation sources “As Low As is Reasonably Achievable” (or simply the ALARA principle).

Purpose

This policy is required as a condition of having a Broad Scope Radioactive Materials License under various federal and state rules and regulations.

Audience

All members of Northwestern University’s research community.

Definitions

The Vice President for Research is the Institutional Official responsible for ensuring an effective Radiation Safety Program.

The Executive Director, Research Safety (RS), is Northwestern University’s representative on the Radiation Safety Committee (RSC) and reports directly to the Vice President for Research.

The RSC is responsible for administrative oversight of the Radiation Safety Program and is comprised of faculty and staff with appropriate expertise. Members of the RSC are appointed by the Vice President for Research. The responsibilities of the RSC are described in section 3.2.1.1., below.

The Radiation Safety Officer (RSO) reports to RS Executive Director and has a reporting option to the Vice President for Research. The RSO is responsible for the implementation, management, improvement and direction, and has oversight of the Radiation Safety Program.

3.1 Regulations

The Illinois Administrative Code (32 IAC Part 340) defines ALARA as making every reasonable effort to maintain exposures to radiation as far below the specified dose limits as is practical through procedural and engineering controls and sound radiation safety principles applicable to the licensed or registered activity. Current regulations acknowledge that some degree of risk may be associated with any exposure to radiation. For this reason, Northwestern works to ensure all use of ionizing radiation remains ALARA.

3.2 University Radioactive Materials Broad Scope License

The Illinois Emergency Management Agency (IEMA) is responsible for regulating use of radioactive material and other sources of radiation and issuing the Type A Broad Scope License.

3.2.1 Broad Scope License

The University’s IEMA-issued Broad Scope License governs possession and use of the following Radioactive Materials:

• Naturally occurring radioactive material
• Source material (uranium, thorium, and certain ores of uranium and thorium)
• Special nuclear material (plutonium and certain isotopes of uranium)
• Byproduct material (most commonly used radionuclides are made as a result of neutron bombardment of material within a nuclear reactor, so they fall under the classification of byproduct material)
• Accelerator produced radioactive material. Examples include: Co-57 and F-18
• Large irradiation sources

3.2.1.1 Radiation Safety Committee

The IEMA requires Northwestern, as a holder of a Type A Broad Scope License, to maintain a RSC, which has three major roles:

• Formulating Policies governing the safe use of ionizing radiation.
• Reviewing proposals for the use of ionizing radiation and qualifications of applicants, and issuing authorizations for such use.
• Reviewing and evaluating the performance of the Radiation Safety Program

3.2.1.2 Authorized Investigators under License

As a general rule, the RSC only grants authorization to use radioactive materials to individuals with formal faculty appointments. The RSC will evaluate the applicant’s relevant training and experience prior to granting authorization. When the RSC judges an applicant has insufficient training and experience for the proposed use, the applicant may be advised to work under supervision of an Authorized Investigator to gain experience. Acceptable training and experience should include:

• Principles and practices of radiation protection as they apply to the requested radionuclide, activity, and procedure
• Radioactivity measurement techniques and instruments
• Mathematics basic to measurements of radioactivity
• Radiobiological effects

3.2.1.3 Radioactive Materials in Human Subjects

The use of radioactive materials in human subjects for diagnosis, treatment, or research is prohibited in University facilities and is specifically excluded in Northwestern’s Broad Scope License.

3.2.1.4 Radioactive Materials in Animals

The use of radioactive materials in animals for research must be authorized by both the RSC and Northwestern’s Institutional Animal Care and Use Committee (IACUC). The ALARA principle and staff training will be followed for the animal use protocol.

3.3 X-ray Registrations

IEMA requires registration of all x-ray producing devices and regulates administration of medical x-rays. Radiation Safety maintains the University’s registrations of x-ray producing devices and is responsible for satisfying IEMA requirements related to such devices. IEMA conducts periodic inspections that include record reviews and physical inspection of x-ray units.

5.1 Security & Accountability

ALARA policy ensures the minimization of the release of radioactive materials. Radioactive materials shall be secured against unauthorized removal from the place of storage. Laboratory doors must be locked when unattended.

Authorized Investigators must ensure that there is a one-to-one correlation between stock vials and inventory records. Inspectors may look at each stock vial and ask to see the associated inventory and usage records.

Report the theft or loss of any source of radiation to Radiation Safety immediately. Call Radiation Safety at 3-8300 (Chicago) or 1-5581 (Evanston) to report the loss. After hours call University Police at 456 and ask them to contact Radiation Safety.

5.2 Violations & Enforcement Actions

The possession and use of radioactive material is a privilege accorded to Authorized Investigators and radiation workers by the Vice President for Research through the Radiation Safety Committee. Each authorization carries with it both explicit and implicit responsibilities for compliance. Authorized Investigators and X-ray registrants are responsible for ensuring that radiation workers conduct their work in accordance with University policies and procedures. An instance of noncompliance by a radiation worker is charged against the Authorized Investigator’s registration.

The privilege of possessing and using radioactive materials or sources of radiation may be lost due to noncompliance with University policies and procedures. The Radiation Safety Committee will review this on a case-by-case basis.