• Authorization
• Classes of Authorization: Description
• How to Apply For Authorization
• Processing and Review of Applications for Authorization

Authorization (top)

1. All persons planning to possess or use radioisotopes at Princeton University must obtain prior approval of the Radiation Safety Committee and/or the "Health Physicist" for each radioisotope. Persons not qualified for authorization, according to the requirements stated below, must use radioisotopes only under the supervision of an "Authorized User."

2. The first step to obtain authorization is the filing of an application through the Office of Environmental Health and Safety. Applicants are advised that the application process may take several weeks (or longer if an amendment to a University license must be obtained) and are, therefore, urged to submit their application sufficiently in advance of the planned starting date to avoid delays. The filing of an application sets in motion a procedure which provides for a thorough review of the radiation safety aspects of the proposed usage. The final step in the procedure is the issuance by the Office of Environmental Health and Safety of an Authorization Number or a Limited Possession Number.

3. Temporary Approval

The "Health Physicist" is authorized by the Committee to grant a temporary approval, if specifically requested by the applicant. However, such approval is granted at the discretion of the "Health Physicist" and is dependent upon receipt of a completed application. Temporary approval is valid for 30 days and is normally issued within 36 hours of receipt of a properly completed application.

4. Duration of Authorization

Each Authorization Number and Limited Possession Number is coterminous with the applicable University license or terminates with the severance from the University of the "Authorized User." In some instances specific expiration dates are established at the request of the "Health Physicist."

5. Revocation

The Committee has the right and responsibility to revoke any authorization granted by it if, in its opinion, sufficient justification exists for such action.

6. Amendments

Any change in the use of a radioisotope from that described in the application shall be discussed with the "Health Physicist." Significant changes which could affect radiation safety, such as the use of an open source as opposed to a "Sealed Source," the in vivo use of radioisotopes in animals as opposed to in vitro work, use of dry powders instead of a less hazardous form, etc., require an amendment. Any such amendments may be approved by the "Health Physicist" except that the "Health Physicist" has the option to refer proposed changes to the Radiation Safety Committee. Increases in the amount of radioisotope authorized for use require a new application.

Classes of Authorizations: Description (top)

Authorization Numbers

There are two kinds of Authorization Numbers: one for Radioisotopes and one for Activations. They are distinguished as follows:

• A Radioisotope Authorization Number authorizes possession and use of the requested amount of a specific radioisotope (and its daughters) in accordance with the statements and representations made in the application. Radioisotopes are generally acquired by purchase from a commercial supplier.
• An Activation Authorization Number authorizes activation of a sample for radioisotope production in an accelerator, reactor, etc., and subsequent possession and use of the product radioactivities in accordance with the statements and representations made in the application. Several types of activations are recognized and are explained in paragraph 3 below.
• Only persons who are "Principal Investigators," hold a faculty or research position, and have had significant previous experience with radioisotopes similar to those being requested may apply for an Authorization Number. However, upon recommendation of the Department Chairman and with concurrence of the "Health Physicist," the requirement for a faculty or research position may be waived provided the applicant has had extensive radioisotope experience or the radiological hazards associated with the use of the radioisotope are minimal.
• The amount of radioactive material and the scope of work permitted under an Authorization Number is, in general, limited by the terms and conditions of the relevant University license.

Limited Possession Numbers

• A Limited Possession Number is a restricted or limited Authorization Number. The scope of the activities permitted and the required qualifications of the applicant differ in the following ways:
  • The applicant does not have to meet the qualifications established for a "Principal Investigator." Less emphasis is placed on previous experience with "Sources of Radiation." Therefore, the scope of work permitted is restricted.
  • The maximum amount of radioactivity authorized for use by an individual holding a Limited Possession Number is limited to 100 times the amount listed in Appendix C of a single radioisotope or the equivalent prorated quantity of several as illustrated in the footnote to Appendix C, except that the total amount for any radioisotope may not exceed 15 mCi. However, persons holding at least one valid Authorization Number and therefore meeting the qualifications of a "Principal Investigator" may hold an unlimited number of Limited Possession Numbers, provided no single quantity authorized exceeds the amount described above for a single radioisotope.
  • Limited Possession Numbers are issued at the discretion of the "Health Physicist" and without Committee review, although the Committee is periodically informed of all new Limited Possession Numbers issued. The "Health Physicist" may, at his or her discretion, elect to require full Committee review.
• Limited Possession Numbers are also issued to authorize possession of "Generally Licensed Devices," such as smoke detector heads, spark gaps, thickness gauges, etc., which contain radioactive material. The licenses for all such devices have general requirements, the specifics of which are dealt with in the application process.

Categories of Activation Authorizations

An "onsite-internal" activation for radioisotope production is one performed at a University facility by and for University personnel and their collaborators. Persons desiring authorization must obtain an Activation Authorization Number.

There is also the case of "onsite-internal" irradiations not performed for the specific purpose of radionuclide production, which may cause the incidental activation of target holders, machine components, shielding, etc., e.g. target irradiations to produce secondary particle beams. The irradiation may be arranged at the discretion of the "Authorized User" responsible for the facility, and no Authorization Number is issued, provided the irradiation meets the following criteria:

• It is performed with the active participation of an individual associated on a full-time basis with the University facility at which the irradiation is done; and,
• No activated material will leave the facility in which the material was incidentally produced.

The "Authorized User" may, however, request a review of the proposed irradiation by the "Health Physicist" and the Radiation Safety Committee. The "Authorized User" has the responsibility for radiation safety, including the inventory and management of any radioactive materials produced.

An "onsite-external" activation is one performed at a Princeton University facility to produce radioactive materials used by non-University personnel at either an on or off campus location. Regardless of where the material is ultimately taken, any person desiring such an activation must file an application for an Authorization Number with the Radiation Safety Committee through the Office of Environmental Health and Safety. If the proposed use includes any transport of the activated material outside the facility at which it was produced, a formal agreement (part of the application procedure) must be executed by a duly authorized representative of the applicant's organization. Certain conditions regarding such activations have been established by the New Jersey Bureau of Radiological Health. These are:

• The person desiring the activation must demonstrate to the Office of Environmental Health and Safety that his or her organization is duly authorized to possess and use the requested materials under the provisions of an appropriate government license.
• The "Health Physicist" is responsible for reporting the transfer on the next monthly radioisotope inventory, indicating the amount of activity, and the date of transfer, the recipient, and the address of organization.

An "offsite" activation is one performed for Princeton University personnel at an off campus facility not owned or operated by the University when the resulting radioactivity, however small or purified, is to be brought on campus. Persons desiring such an activation must obtain an Activation Authorization Number.

How to Apply for Authorization (top)

• Obtain the necessary forms from the Office of Environmental Health and Safety and discuss the proposed work with the "Departmental Safety Manager" and the "Health Physicist."
• Complete the forms, making sure that they are consistent with the guidelines given in Section B above for Authorization Numbers or Limited Possession Numbers. Please type or print in black ink.
• Consult with the "Health Physicist" to review the proposal and to obtain any assistance needed to complete the application.
• Sign the completed application and obtain the signature of the "Departmental Safety Manager" (or in his or her absence the signature of the department chairman). Forward the completed application to the Office of Environmental Health and Safety.
  

Processing and Review of Applications for Authorization (top)

1. Authorization Numbers

Upon receipt of a completed application:

• The "Health Physicist" reviews the application, interviews the applicant, inspects the proposed facilities, and, on the basis of the information obtained, recommends either that the application be approved, conditionally approved, or denied. At this time, if requested, the thirty day temporary approval will be considered.
• Copies of the application with the "Health Physicist's" recommendations regarding approval or denial, any conditions suggested by the "Health Physicist," and all supporting documentation are sent to the Radiation Safety Committee.
• Each member of the Committee reviews the application and may approve, conditionally approve, or deny it. Since an application must be unanimously approved by all available Committee members, a reasonable attempt is made to remove any objections and resolve any concerns. Before making a final decision, committee members are urged to discuss with the "Health Physicist" and the applicant any conditions they wish to impose and objections which could lead to a denial. The Committee members sign the application, annotating it with any comments or conditions, and return it to the Office of Environmental Health and Safety. Denials must be specifically indicated.
• Following final processing and review of the application, the applicant is notified by memo that the application has been approved and authorization granted. Copies are sent to the Chairman of the Radiation Safety Committee and "Departmental Safety Manager." This memo indicates the Authorization Number that has been assigned, the relevant University license, and any conditions or other pertinent information. A copy of the application and all supporting documentation is also returned to the "Authorized User."
• If the application is denied, a copy of it and all supporting documentation is returned to the applicant, indicating the reasons for denial. The applicant may appeal the decision at a special meeting of the Radiation Safety Committee, requested through the Secretary of the Committee.

2. Limited Possession Numbers

• The procedure followed for a Limited Possession Number is the same as that for an Authorization Number except that:
• The application and supporting documentation is not distributed to the Radiation Safety Committee and the Committee does not review the application.
• The Committee is notified of all Limited Possession Numbers issued by the "Health Physicist."