Temporary Job Site, Higher Activity, and an Uncertified Helper
On 14 March the radiation safety officer (RSO) of a small industrial radiography company reviews job files. The company licence authorizes Ir-192 sources up to 3.7 TBq and requires written notice to the regulator at least 7 days before any temporary job site away from the licensed address. A crew worked on 9–10 March at a fabrication yard 85 km away. The exposure device contained a 4.0 TBq Ir-192 source. No pre-job notice was sent. The transport driver’s radioactive-material driver certificate expired on 28 February, and a newly hired helper, who has no radiographer certification, operated the crank for one exposure while the certified radiographer watched from the barrier. The client has already paid the invoice. The RSO must decide what to do before the next job on 16 March.
1. List the non-compliances in this file and explain why each matters, not just that it is a paperwork issue.
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The file contains at least four substantive non-compliances. First, the source activity was 4.0 TBq against a licence limit of 3.7 TBq. This is not a rounding issue: activity drives the dose rate, the controlled-area distance, shielding and the emergency plan. Operating above the licensed activity means the safety assessment for the job may be invalid. Second, the crew used a temporary site 85 km away without the required 7-day written notice. The notification condition exists so the regulator can check local conditions, storage, security and emergency arrangements. Third, the driver’s certificate expired on 28 February, so the transport was not performed by a currently certified driver. Fourth, an uncertified helper operated the crank, which is a source-control task restricted to trained radiographers. Even if the certified radiographer was watching, the helper was placed in a position requiring radiation-protection judgement and source-handling competence. The activity and temporary-site issues also affect the client’s site-specific risk assessment. The RSO should treat this as a significant compliance event, not a clerical correction, because two of the breaches concern control of the source and one concerns the transport chain.
2. Set out the immediate actions for the next 24 hours, including what is said to the client and what is put in writing.
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Immediately suspend the 16 March job until the source, crew and documents are verified. Secure the exposure device in the licensed storage bunker, confirm the source is fully shielded with a survey, and do not move it until the activity discrepancy is resolved. Check the dosimetry records for the radiographer, helper and driver; interview the crew separately and preserve the job log, transport documents, survey records and the client’s work order. Notify the regulator promptly under the licence’s incident/notification provision, stating the facts known: activity, dates, missing notice, expired driver certificate and uncertified operation. Do not wait for a full investigation to make the initial notification. Tell the client that the 16 March work is postponed pending an internal compliance review, and give a realistic revised date; avoid statements that the job was unsafe unless the dose records show an exposure concern. Put the suspension, source security check, notification time, persons contacted and preservation of records in writing to the RSO file. Arrange a replacement certified radiographer and a driver with a current certificate before any restart.
3. Propose corrective actions that prevent recurrence, with owners and records.
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Corrective actions should address each breach. The RSO should determine whether the company needs a licence amendment for 4.0 TBq sources or should restrict field use to ≤3.7 TBq; the dispatch supervisor should add a licence-activity check to the job pack. A temporary-site procedure should require the 7-day notice, regulator acknowledgement and a site-specific assessment before the crew leaves. The transport coordinator should maintain a certificate-expiry register with a 60-day trigger and a second check at dispatch. The training lead should revise the helper’s role: helpers may carry barriers and equipment but may not operate the crank, disconnect the drive cable or approach the guide tube unless under direct, documented supervision and after radiation-safety training. A monthly RSO audit should sample job files for activity, location, driver certificate and crew certification. Records should include the investigation report, root-cause analysis, revised procedures, training attendance, disciplinary or coaching notes as required by company policy, the regulator’s correspondence and evidence that the 16 March job was checked before restart. The client file should record the postponement, revised plan and any contractual communication. Follow-up should be tracked to closure with named owners and dates.