United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

10 CFR 34.2 (b) and (c) - Definitions of Radiographer and Radiographer's Assistant

HPPOS-187 PDR-9111210293

Title: 10 CFR 34.2 (b) and (c) - Definitions of

Radiographer and Radiographer's Assistant

See the excerpt from the NRC Inspection Manual entitled as

above and dated June 13, 1974. This section states that a

radiographer must be physically present at the site when

radiography is taking place. Any individual who assists a

radiographer by manipulating devices or instruments acts as

a radiographer's assistant and must meet the requirements

of 10 CFR 34.31 (b).

As specified in 10 CFR 34.2 (b), a "radiographer" means any

individual who performs or who, in attendance at the site

where the sealed source or sources are being used,

personally supervises radiographic operations and is

responsible to the licensee for assuring compliance with

the requirements of the Commission's regulations and the

conditions of the license. 10 CFR 34.2 (c) defines a

"radiographer's assistant" as any individual who, under the

personal supervision of a radiographer, uses radiographic

exposure devices, sealed sources or related handling tools,

or radiation survey instruments in radiography.

Licensing has construed (with OGC concurrence) these

definitions to mean that a radiographer must be physically

present at the site where the radiography is taking place.

This does not mean in the vicinity of or near the site of

exposure, but the site where the actual radiographic

operation is being conducted. A radio-grapher's assistant

may not perform any operation unless the radiographer is

physically present to personally supervise the operation.

1. The duties and responsibilities of the radiographer

may not be delegated to a radiographer's assistant, and

2. Any individual who assists a radiographer by

manipulating radiographic exposure devices, sealed sources,

related handling tools, or survey instruments is acting in

the capacity of a radiographer's assistant and must meet

the requirements of 10 CFR 34.31 (b).

It is possible for a radiographer to supervise the

activities of more than one radiographer's assistant. For

example, an in-plant operation with more than one

radiographic cell could involve a number of radiographers'

assistants and only one radiographer. In such a situation,

the radiographer would need to be physically present while

any manipulation of the exposure devices or survey

instruments were being performed.

It is usually the intent of radiographic licensees to

qualify individuals to act as radiographers. The vast

majority of programs do not have "career" radiographers'

assistants. The designation of radiographer's assistant is

usually intended for a person being trained as a

radiographer and who must meet the requirements to act as a

radiographer's assistant in order to gain the necessary

experience to qualify as a radiographer.

Regulatory references: 10 CFR 34.2, 10 CFR 34.31

Subject codes: 1.3

Applicability: Byproduct Material

Page Last Reviewed/Updated Thursday, March 29, 2012