Regulatory Requirements for Research Projects using Radiation Sources - Procedures

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1. Purpose and Objectives

This procedure provides information on the regulatory issues facing researchers who need to use ionizing radiation in their work. This document aims to provide guidance through the regulatory requirements in order for researchers to understand what their compliance requirements are and who can assist them.

2. Definitions, Terms, Acronyms

EME - Electromagnetic Energy

RPA - Radiation Protection Advisor

RSO - Radiation Safety Officer 

RSPP - Radiation Safety and Protection Plan

3. Procedures Scope/Coverage

These procedures consider only the radiological safety aspects of the radioisotopes being used. The chemical hazards associated with the isotopes should be assessed separately. 

4. Procedures Statement

Radiation sources include both ionising radiation and non-ionising radiation, encompassing isotopes, electromagnetic radiation, lasers, X-rays etc. Research work involving the use of radiation is highly regulated at both the State and Commonwealth level. It is important that researchers understand the various requirements that apply to them regarding the legislative requirements. The following sections provide advice on different areas of research involving radiation.

5. Legislative Framework for Radiation

5.1 Ionising radiation and lasers in medicine 

The Qld Department of Health - Radiation Health, regulates the use of ionizing radiation sources and laser application in medicine. Radiation Health administers the Radiation Safety Act Qld (1999) which covers all applications of ionizing radiation for health of both human and animals. Radiation Health also provides radiation safety advice to other Queensland government departments such as Environment Heritage Protection and Natural Resources and Mines.

5.2 Electromagnetic radiation and lasers (non-medicine)

The Department of Justice and Attorney-General (DJAG) - Workplace Health and Safety Queensland (WHS Qld), regulates laser applications and other uses of Electromagnetic Energy (EME) in the workplace for example microwave welding machines; laser cutting machines; magnetic fields from power lines etc.

With regards to the Electromagnetic spectrum used in the communications industry the Federal Government regulates this use through the Australian Communications and Media Authority (ACMA) and the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA) these bodies advise nationally on the safety to non-ionizing radiations used in the telecommunications industry and power industry.

The reason for involvement by so many different government departments is that the EME spectrum embraces a wide range of wavelengths with a wide variety of uses by very different industries. For example, the health industry makes extensive use of the X-ray part of the EME spectrum while the telecommunications industry uses the radiofrequency part of EME spectrum.

6. Requirements for Projects Involving Radiation

6.1 User licensing

Users of radiation sources, whether X-ray or radioactive substances, are generally required to hold use licences under the state Radiation Safety Act 1999. Some sub-licensable sources, or those with significant engineering controls, may be used by unlicensed persons under exemptions given in the subordinate legislation - the Radiation Safety Regulation 2010. Persons in training to use radiation sources for which a use licence is required may do so while unlicensed only under the direct supervision and in the presence of an appropriate licensee. Persons who need to apply for a licence have to complete both theory and practical training in radiation safety relevant to their work. The HSW Division offers theory training for the most common radiation practices at the University. Basic practical training is given by the RPA, and specific practical training is provided by the school and centre RSOs or appropriately experienced researchers who hold use licences.

For medical, veterinary and dental radiation apparatus a trainee licence is required, and the trainee must work under supervison of a licence holder.

6.2 Facilities and equipment - compliance certificates

Compliance certificates are required for laboratories and radiation-emitting equipment such as X-ray machines and soil moisture gauges. Researchers should confirm the compliance status of the facilities and equipment they will be using with their RSO.

6.3 Approvals to acquire

When researchers wish to obtain radioisotopes or buy a new piece of radiation apparatus or sealed source equipment, they need to ensure that their school or centre has a specific Approval to Acquire issued under the Radiation Safety Act.

  • Approvals to acquire unsealed radioisotopes are issued for either one-off or continuing supply;
  • Approvals for sealed sources or X-ray machines are only issued on a one-off basis;
  • Sending equipment to the supplier for repair or maintenance will also require approvals.

The local RSO can advise regarding the status and nature of their school’s or centre’s continuing approvals and assist in applying for a new approval if one is necessary.

6.4 Radiation Safety and Protection Plans (RSPP)

Each school or centre with a possession licence has an RSPP approved and certified by Queensland Health under the legislation. These plans include safe working and emergency procedures relevant to the practice and must be complied with by all authorised users. The RSO should supply new users with a copy of the plan or make one available at an easily accessible location to allow users to become familiar with the requirements applicable to their work.

6.5 Project approvals

Licenced users must submit details of their research projects to their RSO for review and approval by the RSO and the University RPA. This is a provision of all of the University's RSPPs that relate to unsealed source use or the use of certain analytical X-ray units.

Detailed justification of the use of ionizing radiation in particular research projects will generally not be necessary provided the proposal has valid research objectives and does not involve the use of radiation where other readily available lower hazard techniques exist. The initial discussion of a project with the local RSO and if necessary, the University RPA, should be the stage at which any such concerns are resolved. Where the particular use of radiation is a new one, or involves techniques that are not well established, the submitting researcher must identify whether alternatives to ionizing radiation exist and cite reasons for the use of radiation sources in the project.

Project approval forms are available from the HSW Division for the following practices:

  • Analytical X-ray (only for equipment that is not fully enclosed);
  • Unsealed radioactive substances in research;
  • General use of ionizing radiation in research (for projects other than biomolecular work and X-ray analysis).

The forms should be read in conjunction with the procedure that deals with the Risk Management and Approval Process to work with Radiation Sources.

7. Customs-Prohibited Import Approval (Radioactive Substances Only)

Where a researcher wishes to import radioactive materials into Australia, they must obtain approval for the import from the Australian Radiation Protection and Nuclear Safety Agency (ARPANSA).

Note: Where the radioisotopes are to be purchased from a supply company with an Australian agent, import arrangements are often undertaken by the agents themselves, who may have a 12 month permit for a particular class of isotopes, e.g. for import of P-32 sources for biomolecular research. This is a commonwealth requirement that is independent of the approvals to acquire issued by Queensland Health, although both may be required and ARPANSA always seek confirmation from state authorities before issuing an import permit. Assistance should be sought from the local RSO regarding requirements for customs-prohibited import release.

8. Use of Materials Regulated by the Nuclear Non-Proliferation (Safeguards) Act 1987

Various isotopes of uranium and thorium are subject to this commonwealth legislation and the University maintains a permit issued under that Act that allows their possession. The most common of these materials is uranyl acetate which is used in electron microscopy. University schools and centres that possess prescribed amounts of these materials are also required to hold possession licences under the state legislation. In addition, where the amounts to be used by individual researchers exceed Schedule 1 of the Radiation Safety Regulations 2010, appropriate use licences must be held and the various other requirements described in this document shall apply.

9. Sub-Licensable Levels for Radioisotopes Used in Unsealed Form

Under Schedule 1 of the Radiation Safety Regulations, 2010 radioactive substance means radioactive material containing more than the concentration or activity of a radionuclide prescribed under a regulation. For allowable concentrations and activities of isotopes in research refer to the Radiation Safety Regulation 2010.

10. Disposal

Disposal of radiation waste should be done in accordance with Schedule 3 of the Radiation Safety Regulations, and refer to PPL 2.80.05 Management of Unsealed Radiation Waste for guidance.

11. Contact for Further Information

Contact your local Radiation Safety Officer, or 

HSW Division Radiation Protection Advisor

Director, Health, Safety and Wellness Mr Jim Carmichael
Director, Health, Safety and Wellness Mr Jim Carmichael