U.S. Nuclear Regulatory Commission
Technical Assistance Request, NRC Licensed Facilities Requesting to Name a Consultant Physicist as their Full-Time Radiation Safety Officer
Title: Technical Assistance Request, NRC Licensed
Facilities Requesting to Name a Consultant Physicist as
their Full-Time Radiation Safety Officer
See the memorandum from J. E. Glenn to M. M. Shanbaky dated
October 18, 1990. This NMSS memo responds to a technical
assistance request from Region I, dated July 10, 1989,
regarding an amendment request from an NRC licensee who
wished to name a consultant as its full-time Radiation
Safety Officer (RSO). Included with the memo is a list of
issues that should be addressed prior to approving a
consultant as RSO. HPPOS-306 contains a related topic.
Qualified individuals, as outlined in 10 CFR 35.900, may be
appointed RSO to an NRC license issued under 10 CFR 35
provided the individual commits to being physically present
at the facility for a specified amount of time in order to
satisfactorily perform duties of the RSO. The specific
time necessary is commensurate with the requirements of the
facility and must be determined on a case-by-case basis.
The time commitment must be during normal working hours to
provide the opportunity for interaction between the
consultant and licensee management.
Clarification as to the individuals availability to respond
to questions, incidents, and/or emergencies, both by
telephone and on-site is needed. However it should be
noted, that there will be some programs where it would be
inappropriate to designate a consultant as RSO. These
include programs involving radiopharmaceutical therapy,
teletherapy, and large scale users of byproduct material.
The licensee must agree to the above as a license
commitment with the caveat that if at a later date the
number of hours and days spent by the RSO at the facility
or the consultant's availability are insufficient to
fulfill the responsibilities required, the program will be
re-evaluated and adjustments made.
Any licensee requesting to designate a consultant as RSO
should be reminded that 10 CFR 35.21 (a) states "the
licensee, through the RSO, shall ensure that radiation
safety activities are being performed in accordance with
approved procedures and regulatory requirements in the
daily operation of the licensee's byproduct material
program." The use of a consultant as RSO does not negate
the responsibility of the licensee to ensure the safe use
of byproduct material.
A list of issues that should be addressed prior to
approving a consultant as RSO is included as an enclosure
to the memo. These issues were derived from questions from
a similar request for technical assistance by Region III.
The list of issues, which was reviewed and expanded by NMSS
staff, should be addressed in the review process of any
request by a licensee to use a consultant as an RSO.
Regulatory references: 10 CFR 35.21, 10 CFR 35.900
Subject codes: 1.4, 1.5