Radioactive Materials

Exemptions for postponing the fingerprinting* and background checks for renewal of a T&R clearance will only be granted on a case-by-case basis. There will be NO exemptions granted for new employees who have never been through the T&R process. New employees will have to be escorted until such time as they are able to complete the process. Licensees should submit the following information with the request for postponement for renewals:

• A statement that the licensee will maintain a list of the names of the individuals who are due for renewal but are currently unable to complete the renewal process.
• The reasons the renewal process is unable to be completed at this time.
• A description of the measures the licensee will take to ensure that those individuals implementing the security program possess and maintain the knowledge, skills, and abilities to carry out their assigned duties and responsibilities effectively.

* The NRC office that handles fingerprint cards has changed. More information can be found in the NRC information notice, STC-20-039 (PDF).

The new address is:

U.S. Nuclear Regulatory Commission
Director, Division of Physical and Cyber Security Policy
Attn: Criminal History Program/Mail Stop – T-08B20
11545 Rockville Pike
Rockville, MD 20852

A licensee may not operate licensed activities without a RSO. If the business is closed on a specific day such that no activities will be performed that day, then it is okay for the RSO to also be furloughed that day. However, if licensed activities are continuing, the RSO must be available and able to respond to any radiation questions or emergencies.

If you are told the business or location you work for is being closed but radioactive material is stored at that business or location, please secure the material and contact DOH as soon as possible. Contact DOH at RadioactiveMaterials@doh.wa.gov or by phone at 360-236-3300.

Yes, the SBD form must be notarized in order to have the discount applied to your account. If you send a form that has not been notarized, you will not receive the discount.

The Radioactive Materials Section will not be performing most types of inspections of facilities for the duration of this event. This decision has been made to protect the health and safety of inspectors and licensees alike. In addition, we understand that for our medical licensees, pulling critical staff off the floor for inspections is not the best use of their time during this event. Allegation and incident investigations, security related inspections, and high risk inspections such as industrial radiography work may still be performed during this time. These inspections will be announced. If the licensee cannot support the inspection during this time due to staffing issues, safety concerns, etc. please let the inspector know when they call to schedule the inspection. The Department of Health will reschedule the inspection for a time that works better for the licensee or as soon as possible after the COVID-19 event is over.

If the source, or device containing the source, is being actively used, it will be leak tested. Any sources not currently being used can be considered to be “in storage” for the duration of this event and will not need to be leak tested regardless of whether or not they were put officially into storage. However, these sources will need to be leak tested prior to being put back into service. Document the justification for not completing the leak tests at the regularly scheduled interval. You will not be cited. DOH will consider additional exemptions on this topic on a case-by-case basis.

Please send requests to:
RadioactiveMaterials@doh.wa.gov

The waiving of training requirements or approval of alternate training will only be evaluated on a case-by-case basis. Your request for accommodations should be sent to RadioactiveMaterials@doh.wa.gov. The request should include the name, training records, and experience of the individual providing the alternate training, training criteria that includes subjects covered and compatibility with manufacturer training, and an RSO/management statement that the trainee will complete manufacturer training once it becomes available.

If the instruments are being used for quantitative purposes such as package receipt or patient discharge surveys, the meters must be in calibration. Meters used in areas that are closed for the duration of the COVID-19 response and meters used for only qualitative purposes (such as surveys checking to see if radiation is present) need not be calibrated during this time. You will need to send them for calibration at the earliest possible opportunity after the response to this event is over. Document your justification for not having all meters calibrated on schedule and you will not be cited.

Department of Health guidance will allow for certain accommodations on a case-by-case basis.

Please send accommodation or licensing requests to:
RadioactiveMaterials@doh.wa.gov.

No. While we encourage the committee members to stay in touch on any radiation issues related to the health and safety of staff, patients, and members of the public, we understand that pulling people away from critical tasks for an RSC meeting is not the most effective or important use of time during this event. If you do decide you need to suspend meetings, please document the justification for skipping or postponing the meetings for the next time you are inspected. You will not be cited.

No. Many licensees will need to close labs, shops, warehouses, and other work areas during the response to the COVID-19 event. For those areas, please either dispose of the radioactive material or secure it. We will consider these areas to be for “storage” only for the duration of this event. Surveys will not be required for storage areas during this time. Please document the justification for not performing surveys for the next time you are inspected. You will not be cited. Once you return the area to radioactive material use, you will need to start surveying again.

Dosimetry is a health and safety necessity for those people who have the potential to receive 10% of the annual limits in WAC 246-221. Dosimetry is often the only way to identify overexposures, unsafe work practices, and unusual events. For anyone who is actively working and has potential to hit these limits, dosimetry needs to continue to be worn and exchanged at the appropriate intervals. For workers who are currently not working in or near a source of radiation or who have dosimeters only because of very conservative procedures at the licensed facility, exchanges are not necessary at this time. You will need to justify and document the reason the workers do not currently have the potential to reach the 10% limits. This could be in the form of written documentation stating that the worker(s) is working from home and will not have access to a radiation area, previous dose records (one year of records is sufficient) showing they have never reached the 10% limits, etc. If properly documented, you will not be cited during your next inspection. As soon as you are reasonably able after the COVID-19 response is over, but no more than 1 year from now, you will need to have the dosimeters processed.

In order to issue a Timely Renewal Letter to extend the expiration date of a current license, we will need a signed application. If you cannot gather all the request information on the application at this time, that's okay. Get us what you can and ensure the application is signed. That is enough for us to issue the Timely Renewal Letter. We can work with you on getting the rest of the documentation at a later date.