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UTAH RADIATION CONTROL BOARD POLICY - adopted May 21, 1993
BACKGROUND
Utah Radiation Control rules prescribe requirements for the issuance of specific licenses of broad scope. Specific licenses of broad scope are subject to a condition that, unless authorized by the Executive Secretary, persons with a broad license shall not conduct activities for which a specific license issued by the Executive Secretary under R313-22-75 or R313-32-18 is required [see R313-22-50 (5) (a) (iii)]
The special requirements for a specific license identified in R313-22-75 describe controls for licensing the introduction of radioactive material in exempt concentrations, the distribution of radioactive material in exempt concentrations, the manufacture and distribution of devices to persons generally licensed, the manufacture and distribution of radiopharmaceuticals, and a number of other regulated activities. The addition of any one of the specific licensed activities, listed above, to a license of broad scope would require authorization by the Executive Secretary pursuant to R313-22-50 (5) (a) (iii).
The activities authorized by licenses of broad scope serve to fulfill the beneficial uses of radioactive material within the confines of the licensee’s facilities. For example, licensed materials are used for medical diagnosis within the facilities controlled by an academic institution. The use does not generally involve other radioactive material licensees. However, the activities identified in R313-22-75 involve other persons because of the distribution of radioactive material to a licensed recipient.
The DRC has issued the following licenses of broad scope:
| LICENSEE | TYPE OF USE |
|---|---|
| University of Utah | Academic/Medical |
| Brigham Young University | Academic |
| Utah State University | Academic |
| Weber State University | Academic |
| LDS Hospital | Medical |
| Data Chem | Industrial |
| Pharmaceutical and Diagnostic Services | Nuclear Pharmacy |
PURPOSE
It is the purpose of this Policy Statement to give guidance to the Executive Secretary when considering licensing actions for licensees of broad scope pursuant to R313-22-50 (5) (a) (iii).
DISCUSSION
DRC staff has concerns about the wide variety of radioactive material usage by a facility approved for academic research and development as well as medical use of radioactive material. As separate licenses issued under R313-22-75 and R313-32-18, each type involves significant quantities of radioactive material, high rates of utilization, and potential for exposure to the public. The action of placing these two types of use within one license, as may be authorized by R313-22-50 (5) (a) (iii) may create a practical limit for effective licensing and inspection purposes by regulatory personnel as well as a practical limit for safety issues effectively controlled by the licensee’s Radiation Safety Committee.
CONCLUSION
It shall be the policy of the Radiation Control Board that the Executive Secretary consider the applicant’s practical limits for safely controlling sources of radiation before approving or denying a license of broad scope pursuant to R313-22-50 (5) (a) (iii).
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