Topic

Policy and Delegation of Authority

Mission Statement

Organization for Control of Ionizing Radiation

U.S. NRC Licenses and Radiation Source Permits

Inspections and Audits

Policy and Delegation of Authority

The radiation safety policy of the U.S. Department of Agriculture (USDA) is found in Departmental Regulation 4400-5. This policy states that:

The U.S. Department of Agriculture will comply with all applicable Federal, State and local laws and regulations governing the use of radioactive materials and equipment that produces ionizing radiation.

The USDA will protect its employees, the public, and the environment from the risk of hazards which might be caused by the use of such materials and equipment.

- Delegation of Authority

The responsibility for the USDA Radiation Safety Program is delegated from the Secretary of the Department of Agriculture to the Assistant Secretary for Administration, who is the Department Safety and Health Official (DSHO).

Operational and administrative aspects of the Radiation Safety Program are delegated from the Assistant Secretary for Administration through the Office of Procurement and Property Management (OPPM), to the Director, Radiation Safety Staff.

The Director, Radiation Safety Staff serves as the Department's Radiation Safety Officer.

Mission Statement

The mission of the USDA Radiation Safety Staff is to:

- Implement a comprehensive Radiation Safety Program that:

- Protects the Department of Agriculture's employees and the general public from the harmful effects of     radiation; and

- Assures compliance with applicable regulations.

- Provide advice and operational services that support and enhance the Department's research and program objectives.

Organization for Control of Ionizing Radiation

- Departmental Organization

The USDA is organized into seven Mission Areas in addition to the Departmental administrative functions. These Mission Areas are shown below. The Agencies using radioactive materials or x-ray producing equipment are listed in their Mission Area.

Figure 3.1 - 1 General organization of the U.S. Department of Agriculture.
 

- USDA Radiation Safety Committee

A Radiation Safety Committee provides Departmental oversight of, and establishes Departmental policy for the Radiation Safety Program. The Committee consists of members from all Agencies that use radiation sources. In addition, technical representatives provide expertise in such areas as human studies, biotechnology research, animal research, and irradiator use.

The Radiation Safety Committee provides oversight of the Radiation Safety Staff through annual program audits and provides advice and assistance to the Assistant Secretary for Administration, agency heads, and staff officials on matters pertaining to radiation safety.

The organization of the Radiation Safety Committee is shown in Figure 3.1 - 2. Current members of the Radiation Safety Committee are listed in Section 2.1.

- Radiation Safety Staff

The Department's Radiation Safety Staff (RSS) is organized to complement the Mission Area organization of the Department. The RSS health physicists are responsible for providing technical and program management assistance to Agencies within a specific Mission Area. In addition, the Permit Operations Section provides administrative management for activities relating to the issuance and maintenance of radiation source use permits.

The organization of the Radiation Safety Staff is shown in Figure 3.1 - 3. Current employees are listed in Section 2.2.

Figure 3.1 - 2 Organization of the USDA Radiation Safety Committee.
 

The names and telephone numbers for the Radiation Safety Committee members are listed in Section 2.1.
 
 
 

Figure 3.1 - 3 Organization of the USDA Radiation Safety Staff.
The names and telephone numbers for Radiation Safety Staff personnel are listed in Section 2.2.

- Location Radiation Protection Officer

Since the USDA radioactive materials licenses issued by the Nuclear Regulatory Commission apply to all USDA facilities throughout the United States, some radiation safety functions have been delegated to Location Radiation Protection Officers (LRPOs) at those locations. These LRPOs provide essential services and coordination for the local radiation safety program.

The duties and responsibilities of the LRPOs are described in more detail in Section 3.3 - Location Radiation Safety Programs.

-U.S. NRC Licenses and Radiation Source Permits

The USDA has been issued two licenses by the U.S. Nuclear Regulatory Commission (NRC) that authorize the possession of radioactive materials. The USDA is inspected each year by the NRC to verify compliance with these licenses and the regulations on which they are based.

- Broad Scope Radioactive Materials License

License Number 19-00915-03 is a broad scope license authorizing the use of radioactive materials for research and development, in gauging and measuring devices, in field applications, and for research studies in humans at locations throughout the United States, as approved by the Department's Radiation Safety Committee.

- Irradiator License

License 19-00915-06 authorizes the use of cobalt-60 and cesium-137 in self-shielded irradiators as approved by the Radiation Safety Committee. These irradiators are used for irradiation studies of lower animals, insects, plants, seeds, chemicals, infectious agents, and agricultural products, and in sterile insect release programs.

- Radiation Source Permits

The USDA is authorized in its licenses to issue radiation source permits to employees at USDA facilities throughout the country. Permits are issued upon application to the Radiation Safety Staff.

After review of the application, the Radiation Safety Staff will issue a Radiation Source Permit to the applicant, indicating approval to procure radioactive materials or x-ray producing equipment. Specific Permit Conditions and other requirements are included in the permit.

Inspections and Audits

- USDA Radiation Safety Committee

Headquarters Audits

As part of its management oversight, and to maintain compliance with the NRC's requirements for an annual review of the radiation safety program, the Radiation Safety Committee performs an annual audit of the Radiation Safety Staff. This audit assesses the following areas of operation:

- Program management;

- RSS compliance with NRC rules and regulations;

- RSS compliance with NRC licenses and license conditions;

- RSS interaction with the Radiation Safety Committee;

- Effectiveness of communication with USDA field sites; and

- Understanding and implementation of radiation safety requirements at USDA field sites.

Field Audits

To further assess the regulatory compliance within the Department, members of the Radiation Safety Committee visit selected field sites each year to assess the location's implementation of the USDA radiation safety program.

These visits are not intended to duplicate a Radiation Safety Staff inspection. They assess the location's ability to correct deficiencies noted and their implementation and understanding of USDA radiation safety guidance.

Annual Report

The results of the headquarters and field audits are transmitted to the Assistant Secretary for Administration as part of the annual program review required by NRC regulations.

- Radiation Safety Staff

The Radiation Safety Staff has established an inspection program of its locations to assure compliance with the USDA Radiation Safety Program requirements and to assure compliance by the Permit Holder with the requirements in their permit. The objectives of the inspection program are to:

Identify and document any violations of the USDA radiation safety program requirements;

Make recommendations to improve the location's radiation safety program; and

Assure actions are taken to correct violations and implement recommendations.

An inspection schedule is developed in January of each year. The inspection frequency is based on the location's radioisotope use and inspection priority. Generally, locations are inspected every 3-5 years.

LRPOs are notified of the planned inspection to assure that appropriate personnel are available. Area and regional offices are also notified of the planned inspection.

Following the inspection, an exit interview is held with the LRPO and the location management. The results of the inspection are discussed along with any apparent violations and recommendations.

An inspection report, documenting the results of the inspection is transmitted to the location management, and other appropriate officials. Location management must respond indicating the actions that have been taken to resolve the violations or the corrective actions taken to implement the recommendations. After review by the Radiation Safety Staff, and if the report is acceptable, the inspection is closed.