10 CFR 20.203 (f) Enforcement Guidance for Container Labels
See the memorandum from A. F. Gibson to Radiation Support Section dated March 7, 1980. This memo contains enforcement guidance for container labels in 10 CFR 20.203 (f) and states that the purpose of labels is to ensure adequate information is available to enable a worker to handle the materials safely.
The health physics position was written in the context of 10 CFR 20.203, but it also applies to the "new" 10 CFR Part 20, Sections 20.1904 and 20.1905. HPPOS-028 contains a related topic.
A label required pursuant to 10 CFR 20.203 (f) [and 10 CFR 20.1904] must bear the radiation caution symbol and the words "CAUTION, ADIOACTIVE MATERIAL" or "DANGER, RADIOACTIVE MATERIAL", as well as provide sufficient information that includes the radiation levels, kinds of material, estimates of activity, date the activity was estimated, mass enrichment, etc. This is required to permit individuals handling or using the container or working in the area to take necessary precautions to avoid or minimize exposure and ensure worker safety.
Unlabeled containers are almost a certainty in any large facility, such as a power plant. If the discovery of unlabeled containers constitutes isolated occurrences, enforcement action may not be appropriate. However, a very high radiation level container left unlabeled would be a safety hazard, as well as a strong indicator of a defect in the licensee's radioactive materials control program.
Should noncompliance with 10 CFR 20.203 [or 10 CFR 20.1904] be suspected, it must be determined whether control is being exercised by other methods described in 10 CFR 20.203 (f) (3) [or 10 CFR 20.1905].
In addition, the calculations used to determine greater than Appendix C quantities present in the container should be included in the discussion section of the Inspection Report. It must be emphasized to the licensee that the purpose of 10 CFR 20.203 (f) [and 10 CFR 20.1904] is to ensure adequate information is available to workers to enable them to safely handle radioactive materials and minimize exposure.
Regulatory references: 10 CFR 20.203, 10 CFR 20.1904, 10 CFR 20.1905
Subject codes: 4.7, 12.7