People can receive, possess and use “generally licensed” radioactive materials without applying for a specific NRC license, but they must comply with the requirements established for the applicable general license as established by NRC regulations. The EH&S Radiation Safety Office needs to know about WU owned generally licensed sources to minimize any confusion with our specific licensed radioactive materials, and to assist the owner in their regulatory responsibilities and environmental stewardship of these materials. In some cases, the PI and the EH&S Radiation Safety Office may decide that the particular radioactive material may be better or more easily managed if it were incorporated under the University’s specific NRC License.
Some examples are, but are not limited to: antistatic devices such as those used in precision balances; electron capture detectors (ECDs) used on some gas chromatographs; the internal sources in liquid scintillation counters; some calibration or reference sources; some glow-in-the-dark items such as timepiece or instrument dials and “EXIT” signs; chemical compounds containing uranium or thorium such as uranyl acetate used in electron microscopy; some kits used in certain in vitro clinical and laboratory testing; and shipping containers containing depleted uranium shielding.
Each generally licensed item is sold with information included about the NRC’s requirements for the user. Typically these requirements relate to disposal of the device, or return of the radioactive part of the device to the manufacturer when its useful life ends. In some cases other requirements may exist, such as leak testing of sources or notifying the NRC if the device is transferred to another person.
Some products of certain combinations of isotope and quantity of radioactive material are considered “exempt”. People can receive, possess and use “exempt” radioactive materials without the need to have any type of license issued under the Atomic Energy Act and with the requirement to follow NRC regulations. It is helpful for the EH&S Radiation Safety Office to know about WU-owned exempt sources to minimize any confusion with licensed radioactive materials and to assist the owner in their environmental stewardship of these materials.
Some examples are, but are not limited to: check sources for radiation instrument testing or for teaching; some self-luminous products like timepieces and other instrument dials; some smoke detectors; items containing small amounts of thorium such as incandescent gas mantles, vacuum tubes, welding rods and finished optical lenses; isogenerators used in teaching; and materials/items containing small amounts of uranium or thorium such as geological samples, fire brick, glassware and glazed ceramic tableware.
Washington University has an NRC license for the use of radioactive materials. Washington University and affiliated Medical Center organizations are expected (by NRC) to manage all radioactive materials under our Radiation Safety Program, including generally licensed materials. In addition, because the EH&S Radiation Safety Office has experience in managing various types of generally licensed materials, we can help you recognize your regulatory responsibilities and establish your management control for these materials.