Is your lab posted for Radioactive Materials Usage? If yes, then the question becomes: Is your lab ACTUALLY using or storing radioactive material? If the answer is "No," and especially if the answer is "No, not for two or more years," then the Division of Radiation Safety (DRS) strongly recommends you put your lab in stand-by "Dormant" mode. DRS is obligated by NRC requirements and NIH license conditions to perform routine surveys on all posted labs, and these surveys cost time and money. Also, the surveys are an intrusion into your workspace, though hopefully a considerate one. As long as a lab is posted for Radioactive Materials Usage, DRS contractors are required to perform the obligatory routine monthly contamination surveys as well as the periodic comprehensive regulatory compliance surveys. Adjacent corridors must get surveyed, too.
Feedback from our contractors, bolstered by evidence from our own DRS Database of where the radioactive material inventory is located, shows that approximately two-thirds of all active labs in fact are not using or storing radioactive materials at all. What a waste of DRS resources!
If your lab is posted but you haven't been performing radioactive work (or needing to store radioactive samples) for the last two years, please do consider contacting DRS to place your lab in a dormant "No Surveys Needed" state. This will allow cessation of the routine contamination monitoring and regulatory compliance checks and eliminate nearly all visits by the DRS contractors. DRS will swing by and perform a few steps such as performing a final clearance survey, arrange for removal of all radwaste containers, and inspect the lab for any remaining radioactive sources or items. As a final step, the "Caution Radioactive Material" sign will be removed from the lab door, indicating that it is no longer an Active Use space.
What if you want to return to radioactive material usage, or in other words Reactivate your lab? Just contact DRS and your Health Physicist will be glad to replace the "Caution" sign, arrange for delivery of new radwaste containers, and review training, survey meter and shielding needs. This can all be done within two business days. Your lab personnel won't need to repeat formal Radiation Safety training as long as they've kept up with the periodic Refresher trainings offered by DRS. It's possible, and in fact preferred, that potential radioactive material users (i.e., lab bench researchers) keep their status "Active" in the DRS database, and instead just inactivate their lab posting, if the lab group is simply in a phase of No Active Radioactive Material Use.
That's the best way to eliminate unnecessary surveying for radioactive contamination that isn't possible to be present, reduce lab visits by DRS and its contractors, and avoid confusing signage that incorrectly indicates radioactive material may be present. The recent NRC inspection in late 2021 included a comment by one of the inspectors to the effect that NIH was unnecessarily expending resources on maintaining radiation safety requirements in labs with chronic non-use, and NIH management has therefore indicated their desire for DRS to inactivate chronic non-use labs. Will you do your part to boost this risk reduction initiative? Contact DRS at 301-496-5774 to learn more.
