Radiation Safety Program Requirements: What Employers Need to Include
If you use radioactive materials, x-ray equipment, accelerators, or other ionizing radiation sources, you are expected to run a formal radiation safety program. At the federal level, the Nuclear Regulatory Commission requires each licensee to develop, document, implement, and review a radiation protection program that keeps occupational and public exposures as low as reasonably achievable, known as ALARA, and to review that program at least annually.
Appoint a Radiation Safety Officer
Every robust program is anchored by a Radiation Safety Officer. In medical uses of byproduct material, management must appoint an RSO in writing, define the RSO’s authority and duties, and give the RSO enough independence, time, and resources to identify problems, stop unsafe work, and verify corrective actions. Many medical licensees must also form a Radiation Safety Committee that includes the RSO. Temporary or associate RSOs are allowed if qualifications and notifications are met.
Core elements your program should cover
Use this checklist as a starting point. Your specific scope and license conditions will drive the details.
Licensing and registration. Hold the correct NRC or state license for byproduct material. Register x-ray devices or accelerators when required. Keep an accurate source and device inventory.
ALARA and dose limits. Set ALARA goals and procedures that ensure compliance with occupational and public dose limits, and document periodic program reviews.
Monitoring and dosimetry. Provide personal monitoring when workers could exceed action levels or enter high radiation areas. Maintain survey instruments that are appropriate and calibrated.
Training and worker information. Give instruction to workers who are likely to receive more than a minimal dose. Cover hazards, protective methods, applicable rules, and workers’ responsibilities. Keep records.
Posting and labeling. Post radiation areas, high or very high radiation areas, airborne radioactivity areas, and rooms where certain amounts of licensed material are used or stored. Label containers as required.
Receiving and opening packages, leak tests, and contamination control. Follow written procedures that prevent unnecessary exposure and spread of contamination.
Waste management and storage. Use approved disposal pathways and secure storage with proper records until disposal or decay in storage is complete.
Incident response and reporting. Establish emergency procedures, notification thresholds, and reporting lines for abnormal events and exceedances.
Audits and corrective action. Perform routine audits and an annual program review, track findings to closure, and update procedures as needed.
OSHA and the NRC, who covers what
Many workplaces fall under the NRC or an Agreement State for licensing of radioactive material. OSHA still applies in important ways. OSHA’s Ionizing Radiation standard requires employers to control exposure, survey hazards, provide dosimetry, post required signs, and instruct personnel. OSHA also notes additional monitoring triggers, including when a worker is likely to receive a significant fraction of the occupational limit or enters a high radiation area. If the NRC regulates your licensed material, 10 CFR part 20 governs many technical requirements, and OSHA references that interface directly.
Important warning about state requirements
Radiation control is not identical everywhere. Most states are Agreement States, which means they regulate the possession and use of byproduct, source, or special nuclear material within their borders, and they issue the licenses and conduct inspections. Many of these programs sit inside state health departments or environmental agencies. Before you design or update your program, contact your state radiation control program for specific forms, fees, training expectations, and device registration rules. You can find your state contact through the NRC’s Agreement States page and the CRCPD directory of state radiation control programs.
Bottom line
A compliant radiation safety program is more than a binder. It is a living system with clear leadership by the RSO, ALARA planning, training, monitoring, surveys, posting, waste controls, and regular audits. Start with federal requirements, then align with your state radiation control program and your specific license or registrations. If you want help tailoring a practical program for a small shop or a multi-site operation, VanguardEHS can help you design procedures, train your RSO and staff, and prepare for inspections.
