Additional
Considerations for an
RSO
Cindy Cardwell
Department of State Health Services
Radiation Machines
Regulated by States
Varying rules
Can be RSO for both machines and
material uses
Compliance
Inspections by the regulatory agency
Purpose is to determine compliance
Observing operations/practices
Reviewing documents
Performing surveys
Conducting interviews
Non-compliance
Violations of rule will be noted
Summary of violations will be sent to
licensee/registrant
Requires corrective action and response
to the regulatory agency
Enforcement
Methodologies for enforcement actions
vary
May cite violation for failure of RSO to
perform duties and responsibilities
Security
Radioactive materials in quantities of
concern
Additional security requirements
Additional responsibilities for RSO
Emergency Response
Primary contact with the agency
Natural or other disasters
Coordination efforts
RSO Scope
RSO must be on site periodically
commensurate with the scope of
licensed activities
RSO must be capable of physically
arriving at the licensee’s facility within a
reasonable time after being notified of an
emergency situation or unsafe condition
RSO Scope
Substitute RSO?
For up to 60 days in a year if…
Licensee establishes the authority, duties
and responsibilities…
Sub must meet qualification requirements
Multiple RSOs
RSO for multiple licensees
Medical Physicist Licensure
Some states have licensure law
Must meet those laws in addition to the
medical rules
Questions?