ATTACHMENT D RADIATION SAFETY COMMITTEES-NRC REGULATORY COMPLIANCE.pdf

This is a memorandum from the Department of Veterans Affairs addressing Radiation Safety Committee (RSC) compliance and Nuclear Regulatory Commission (NRC) regulatory requirements at VA facilities.

The memorandum, issued June 3, 2011, from the Acting Assistant Deputy Under Secretary for Health for Clinical Operations to VISN Directors, emphasizes that all VHA facilities using radioactive materials under NRC jurisdiction must maintain a properly functioning Radiation Safety Committee as required by VHA Directive 1105.01. The RSC is responsible for leveraging management commitment to improve worker and patient health and safety and ensure NRC compliance. Key deficiencies identified through over 85 unannounced NHPP inspections and 32 NRC inspections include: failure to hold meetings at appropriate intervals with adequate quorum participation (RSCs must meet at least every six months, with quarterly frequency recommended for broad-scope permit facilities); failure to include all prescribed standing agenda items in meeting minutes, particularly radioactive material security and footprint management; failure to approve and remove authorized users with RSO continuity; failure to assign and track action items; failure to submit RSC minutes to internal oversight committees within 30 days of meetings; and failure to obtain Director's signature on minutes within 45 days. The memorandum establishes a 12-month implementation timeline for full DUSHOM memorandum compliance and instructs NHPP inspectors to issue violations for non-compliance. VISN management is expected to take corrective actions as necessary. Additional RSC requirement information is available through referenced VA resources and NHPP at (501) 257-1571.