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Radiography Personnel and Required Qualifications

A. Types of Radiography Personnel

Persons engaged in the actual handling and use of sealed sources and equipment are defined in the regulations as "Radiographer" or "Radiographer's Assistant."

A radiographer is that individual who either performs radiography himself, or who is in attendance at the site of use to personally supervise radiographic operations. The radiographer is the individual directly responsible to the licensee's management for assuring that radiography is performed at all times in accordance with Commission regulations and the conditions of the AEC license.

A radiographer's assistant is any individual who manipulates radiographic exposure devices, sealed sources, related handling tools, or survey instruments while under the personal supervision of the radiographer.

It is important that two points be understood: (a) the duties and responsibilities of radiographer may not be delegated to a radiographer's assistant; and (b) any individual who assists a radiographer by manipulating radiographic exposure devices, sealed sources, related handling tools, or survey instruments is acting in the capacity of a radiographer's assistant and must meet the qualifications set forth in § 31.201 (b) of Part 31.

B. Qualifications of the Radiographer and the Radiographer's Assistant

Sealed sources used in radiography usually contain multicurie quantities of gamma emitting radioactive material and will be hazardous if not used properly. Therefore, each radiographer and radiographer's assistant must meet certain minimum training and experience requirements. A thorough understanding of the hazards and proper procedures for safe handling and use of

radiography sources is a fundamental requirement for any individual who is to assume the duties and responsibilities of a radiographer. Part 31 limits assignment of the duties of radiographer or radiographer's assistant to individuals who meet the requirements for those positions set forth in § 31.201. In order to permit each applicant a choice in the manner of which personnel may be trained to qualify as radiographer, § 31.201 does not specify detailed contents of a training program. Appendix A of Part 31, referred to in § 31.201, itemizes those major areas in which radiographers must be instructed. Radiographers must also be instructed concerning the conditions and provisions of the AEC license under which they will perform radiography and must demonstrate competence to use the radiographic exposure devices, sealed sources, related handling tools, and appropriate survey instruments.

Radiographers must be supplied copies of Part 20, Part 31, the operating and emergency procedures, and the AEC license under which they operate as a radiographer.

An individual who acts as a radiographer's assistant must be instructed as to the licensee's operating and emergency procedures and must demonstrate competence to use the radiographic exposure devices, sealed sources, related handling tools, and survey instruments, which they will handle, under the personal supervision of the radiographer. Each radiographer's assistant must be supplied with a copy of the operating and emergency procedures.

Note that § 31.201 requires radiographers and radiographer's assistants to demonstrate an understanding of the instructions they have received as required by that section, and to demonstrate competence to handle the equipment they will use in their assignment.

It is the licensee's responsibility to determine that a radiographer or radiographer's assistant meets the requirements set forth in the regulations.

C. The Training Program

Except as noted in paragraph D which follows, an applicant for a radiography license must have an adequate program for the training of radiographers and radiographers' assistants. Section 30.24 (g) (2) of Part 30 by reference to Appendix A of Part 31 lists five major categories of subjects which must be included in the training program. These categories must be separately identified and the scope of training in each category fully explained in the license application.

Initial Training

The training program must be sufficiently broad in scope to satisfy the provisions of § 31.201 of Part 31. Some areas referenced in § 31.201, particularly those in Appendix A, are sufficiently technical that an applicant may not have in its employment personnel with sufficient knowledge of radiation principles to provide the required instructions. In such cases, the applicant may specify that initial training will be performed by a qualified consultant or by one of the commercial companies which provide training courses for radiographers. Applicants should describe in detail the training services to be provided by the consultant or commercial concern.

An applicant must identify individuals who will conduct each phase of the training program, and fully describe their training and experience which qualifies them to perform this service. Individuals conducting training programs should have training and experience in excess of that expected of the individuals who receive the training. Training programs should be designed to give the radiographer a practical approach to an understanding of the nature of radiation and its potential hazards. Training would normally consist of both formal instruction and some actual experience.

Training in the first three of five major categories listed in Appendix A is intended to give individuals working with radioactive

material basic understanding of the nature of the radioactive material they will use and its hazards. Radiographers with this fundamental knowledge will be better prepared to understand the reasons for the requirements of adhering exactly to the regulations, operating and emergency procedures, and the conditions of the applicable license.

Instruction must deal specifically with the radiation detection instrumentation, radiographic equipment, and operating and emergency procedures to be used in the radiography program. If consultants or commercial courses are used, the applicant must determine that such training will cover the specific equipment and procedures used in his radiography program.

To operate safely, radiographic personnel must be thoroughly familiar with the operational features of the exposure devices they will use, so that they can safely operate the devices during normal operations and will know what to do in the event of an equipment malfunction including their diagnosis and correction. With respect to survey instruments, radiographic personnel must understand their use, limitations, how to interpret readings, and how to detect malfunctions. They should have general knowledge of radiation levels to be expected during various types of operations. Through a combination of familiarity with the exposure devices, expected radiation levels and proper use of survey instruments, malfunction of equipment can be detected and hazardous situations avoided. For example, under normal conditions, a sealed source retracted into the exposure device and seated in its shielded position will produce certain radiation levels on the surface of the device. Measured radiation levels which are different from expected levels will indicate that the source may not be fully retracted or that the instrument is not functioning properly.

Periodic Training

The training program must provide updated training and instruction to radiographic personnel whenever changes in the radiography program are made. It should include such items as instruction on any

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