The Division of Radiation Safety (DRS) plans to change its method of completing monthly surveys for posted labs to eliminate the risk of missed surveys. Instead of the contractor's service being a voluntary endeavor and require lab payment, DRS proposes that the contractor perform all monthly contamination surveys for all labs, and invoice DRS instead. DRS will provide further information to all labs when it implements the revamped procedure this summer.
Posted labs use/store radioactive material and have a yellow "Caution Radioactive Materials" sign on their door. These labs are required to document a contamination survey once a month, with a copy submitted to DRS for tracking. Even when radioactive materials are not used in a given month, a "No Use" survey submitted via the Authorized User portal still must account for that month and be submitted to DRS. These vital records are reviewed during NRC inspections and compliance with the monthly survey policy maintains our NIH license commitments. Yet, failure to perform/submit monthly surveys has caused multiple Authorized Users (AUs), over the years, to receive a Notice of Violation from the Radiation Safety Officer.
Several years ago, DRS added a new task order in the Regulatory Compliance and Radiation Safety Support (RCS) contract, which allowed DRS contractors to be hired by a lab to perform monthly surveys for them under a pre-negotiated fee. Many labs were happy to take advantage of this service and pay the annual charge, for the relief of never needing to worry about missed monthly surveys. However, this service was never a mandate and about two-thirds of the posted labs continued to perform their own surveys. This was still a substantial number of surveys for DRS to track, and problems remained with issues of completeness, quality and timeliness of survey submission. Notices of Violation were still being sent to AUs who let a month or two slip by without a survey being performed.
DRS is now taking the opportunity to change the routine and eliminate the missed monthly survey risk across NIH altogether. Through the proposed change, non-compliance of missed monthly surveys is eliminated, survey timeliness and quality are assured, and AUs will not receive a dreaded Notice of Violation for any recordkeeping gap. Furthermore, this reduces the perception of DRS being a "policeman of paperwork completion," which is not the reputation the Division wishes to have.
The DRS RCS contract is due for re-solicitation in the Spring of 2020, with an anticipated new contract start date of July 1. Labs who currently utilize the contractor for performance of monthly surveys will not see any change to the routine, except they will no longer need to pay for the service. Labs who currently perform their own surveys should expect the contractor to take on this duty. DRS will communicate directly to all labs as the target date gets closer, so each lab will know and understand the expected change to come. In the interim, if your lab does its own surveys, it should continue to perform and submit them until the new contract takes effect.
For any questions on this upcoming change, please contact DRS at 301-496-5774.
