United States Nuclear Regulatory Commission - Protecting People and the Environment

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

HPPOS-187 PDR-9111210293

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 Tuesday, June 16, 2015