Developing and implementing a written radiation protection program is not an OSHA requirement for general industry but a best practice for protecting workers from ionizing radiation. Yet, according to the agency, a radiation protection program “should” include the following program elements, at a minimum:
- Qualified staff (such as a Radiation Safety Officer (RSO) or health physicist) to provide oversight and responsibility for radiation protection policies and procedures.
- As Low As Reasonably Achievable (ALARA), which is a guiding principle in radiation protection used to eliminate radiation doses that have no direct benefit.
- A dosimetry program in which personnel exposure monitoring is conducted, as required by federal or state regulations, for external dose and, as needed, for internal dose.
- Surveys and area monitoring to document radiation levels, contamination with radioactive materials, and potential worker exposures.
- Radiological controls, including entry and exit controls, receiving, inventory control, storage, and disposal.
- Worker training on radiation protection, including health effects associated with ionizing radiation dose, and radiation protection procedures and controls to minimize dose and prevent contamination.
- Emergency procedures to identify and respond to radiological emergency situations.
- Recordkeeping and reporting programs to maintain all records and provide dosimetry reports and notifications, as required by federal or state regulations.
- Internal audit procedures to annually audit all aspects of the radiation protection program.
Despite no written program requirement in OSHA 29 CFR 1910.1096, Ionizing Radiation, it may be helpful to put a written program in place to organize the complex requirements.
While an ionizing radiation protection program is not required by OSHA 1910.1096, the U.S. Nuclear Regulatory Commission (NRC) regulations for radiation protection programs (10 CFR 20.1101) apply to some specific radiation sources and occupational settings. OSHA is precluded, under Section 4(b)(1) of the OSH Act, from enforcing requirements pertaining to working conditions regulated by another federal agency.
Some states too may regulate occupational exposure to ionizing radiation. Check with your state to find out if it requires a written radiation protection program. OSHA is precluded, under Section 4(b)(1) of the OSH Act, from enforcing requirements pertaining to working conditions regulated by a state agencies acting under section 274 of the Atomic Energy Act of 1954, as amended (42 U.S.C. 2021). Also, note that State Plan States may have more stringent requirements for occupational exposures to ionizing radiation when compared to federal OSHA requirements.
