U.S. Nuclear Regulatory Commission
License Condition, "... Used by or Under the Supervision of..."
Title: License Condition, "... Used by or Under the
Supervision of ..."
See the Interpretive Guide from the IE Manual entitled as
above and dated October 1, 1979. It provides guidance on
the degree of supervision to be exercised by authorized
users, including medical users. An authorized user need
not be present at all times but must be readily available
for consultation. This guidance applies to all materials
licensees except radiography; the requirements for
supervision of radiographic operations are defined in 10
CFR 34. HPPOS-145 contains a related topic.
In developing the following interpretation with members of
the NRC staff and OELD, it was concluded that it was
impractical to try and define numerical times and distances
with respect to supervision availability because of the
wide variations in circumstances. Similarly, it was
impractical to define the frequency of verbal orders or the
performance of audits by supervision since these would
depend in part on the degree of changes in operations,
equipment, personnel, etc. Therefore, considerable
judgment by the inspector (s) in implementing the guidance
will continue to be required.
1. An authorized user named on an NRC license is
considered to be supervising the use of radioactive
materials when he directs personnel in the conduct of
operations involving the licensed material. This does not
imply that the authorized user must be present at all times
during the use of such materials. However, the authorized
user / supervisor is responsible for assuring that personnel
under his supervision have been properly trained and
2. The authorized user / supervisor is therefore
responsible for the supervision of operations involving the
use of radioactive materials whether he is present or
absent. When absent, the authorized user should be
available for consultation (by telephone) in a reasonable
amount of time commensurate with the need for consultation,
based on the adequacy of the training of those personnel
under the user's supervision.
3. For medical programs, the supervising physician
should be located sufficiently close to the hospital in the
event he is needed to personally supervise a procedure or
interpret the results of a procedure. "Sufficiently close"
cannot be defined for the reasons stated above; but the
supervisor should be in the same city as the activity or
close to the city (if it is a small city or town) so that
he can get to the facility in a reasonable period of time.
(Many physicians use a paging system so they can be alerted
to call a hospital if needed.) A supervisor that goes on
vacation or cannot be reached is not considered to be
supervising. Further, for physicians licensed to
supervise, it is necessary that they be available to
interpret the results of a medical procedure whether or not
they actually perform the scans, give injections, etc.
Regulatory references: 10 CFR 30, 10 CFR 35, License
Subject codes: 1.3
Applicability: Byproduct Material