A Tutorial by Stephen M. Karesh, PhD
Adapted for the Web by Stephen M. Karesh, PhD & Marsha Lipps CNMT
|Radiation Safety Inspection Issues
- A technologist is taken aside and asked questions
- The inspector extracts a vial from the waste bin and asks you to show entry of this vial in incoming package logbook.
- The inspector asks you to prove that you performed QC on your dose calibrator when on call on a legal holiday or a Sunday.
- The technologists hands and shoes are monitored without warning.
- GM Counter monitoring of "cold" trash bin
- Monitoring of the treadmill and the surrounding environment.
Guidelines For A Successful Inspection
- Keep the inspector in the back of your mind every working day. Try to think like the inspector when completing documentation.
- Make sure than an item of non-compliance from a previous inspection has been corrected- that’s the first place the inspector will look.
- Don’t panic during an inspection- be confident, polite, and honest. Sense of humor is a plus.
- Don’t offer any information other than what the inspector requests.
- Be personably responsible for your continuing education requirements
- Pay close attention to suggestions and recommendations made during the exit interview.
Murphy’s Law favors the Inspector!
- Linearity checks are usually performed on a timely basis, but often are not taken out to the lowest dose level one would use clinically. A reasonable level is 30 mCi, comparable to doses of iodinated compounds or Cr-51 labeled RBCs
- Inspectors often see people drawing doses, injecting patients, eluting generators and handling eluate without gloves. Be prepared during an inspection- wear gloves if there is a chance you will be working with radioactivity in the inspector’s presence.
- Survey meters must undergo a brief operational check before each use. Results must be recorded at least quarterly as well as after calibration, repair, or battery change.
- Room survey records are not complete unless they include the make, model, and serial # of the instrument used. In addition, if a well counter is used for wipe tests, the make, model and serial # must be recorded in the logbook.
- When performing the Constancy Test on dose calibrators, one MUST check every setting that might be used that day. For example, when called in for a stat lung scan, both the Tc-99m and Xe-133 settings should be checked. Often a ventilation study is added on and one forgets to check the calibrator for Xe-133.
- An annual review of the radiation safety program must be performed by either the Radiation Safety Officer or his designate (may be a consultant). Results must be reviewed by Hospital Administration. An annual review of the ALARA Program must also take place.
- Brachytherapy records must indicate complete accountability for records of all inventory items. There should be a conversion factor for converting Radium units to mCi.
- Rooms in which Xe-133 gas are used must be under negative pressure. Inspectors find failures occasionally when construction is underway and airflow is diverted from Nuclear Medicine to another location, destroying the required pressure differential.
- Frequent failure for unit dose users is the calibration, dating, timing, and initialing the dose record.
- A minor issue is Continuing Education credits. Most NMTs are conscientious, but occasionally license renewal is held up due to failure to obtain enough credits.
- All authorized users are required to undergo radiation safety training on an annual basis.
- Hand monitoring might be required daily, or every time you leave the laboratory, depending upon license requirements for your institution.
- Inspectors like to review High Dose Iodine therapy procedures, especially issues related to dose calibration, patient dose administration procedures and safety precautions taken, and waste disposal records.
- Incoming package logbooks are kept up well, in general. Inspectors are most likely to ask to see log-in of a package received on the weekend or on a holiday.
- Regarding administration of I-131 Na iodide: If the patient has been admitted, then, regardless of the dose of I-131 (whether 8 mCi or 200 mCi), nursing instructions must be distributed, signage must be posted on the door, room surveys must be performed, and all required precautions for the hospitalized radioactive patient must be observed.
- Regarding generator QC testing, the most common failure is to not report Mo-breakthrough as a ratio, e.g., 0.01 mCi mCi/mCi Tc. Those people still using generators are very conscientious about performing the test, even when called in for a stat scan.
- NRC has proposed a check of Mo-breakthrough and Al ion breakthrough at time of first elution. If tests pass, no additional testing is required.
- Not applicable in agreement states
SURVIVING AN INSPECTION
RADIATION SAFETY INSPECTION ISSUES