The Division of Radiation Safety (DRS) is clarifying its policy for obtaining radioactive material that meets the regulatory definition of "exempt quantities". Exempt radioactive material, by definition, is exempt from the terms and conditions of NIH's Nuclear Regulatory Commission license and is described in the Code of Federal Regulations 10 CFR Part 30.71 Schedule B. This new DRS policy will eliminate inconsistency with tracking exempt quantity radioactive materials as part of a laboratory's official inventory. Most of the procedural changes will take place within DRS; however, there are aspects that will be visible to users of these materials.
As a reminder, radioactive material that arrives to NIH above the exempt threshold MUST be treated in all aspects as licensed radioactive material even after it decays below the exempt quantity listed in the regulations. Radioactive decay does not constitute a pathway to possessing exempt quantities. Radioactive material can only be considered exempt if it was shipped by the vendor as exempt material in accordance with an exempt distribution license that the vendor holds.
All radioactive materials are normally delivered to Building 21 (though there are rare exceptions for certain short-lived clinical radiopharmaceuticals). In the case of exempt radioactive material, DRS wishes to continue to be the point of receipt so that we can track all nuclides delivered to an NIH location for long-term recordkeeping purposes. If you procure radioactive material that a vendor describes as exempt from licensing, please DO continue to follow all DRS shipping and receiving requirements unless otherwise granted specific allowance by DRS.
DRS will continue to deliver exempt materials to labs as any other radioactive material delivery, but instead of the standard Utilization/Disposal form, an Exempt Quantity information sheet explaining lab responsibilities will accompany the package. DRS will not place an exempt item on an Authorized User's radioactive material inventory, and these items will not be included in the annual inventory reconciliation. If a lab believes they received exempt radioactive material directly (absence of the information sheet will be a good indicator), DRS wants to be notified so that it can confirm the material is exempt and to know the usage location for recordkeeping purposes.
An important requirement for exempt radioactive material is that it must still be disposed as radioactive waste. Otherwise, labs should handle exempt material in a safe manner consistent with techniques and practices that prevent spread of contamination or ingestion of the material. DRS is always available to respond should there be an issue with exempt radioactive materials. Questions? Contact a DRS health physicist at 301-496-5774.
