Radiation Management Plan Example Veterinary Radiography Radiation Protection Unit GPO Box 125 Hobart TAS 7001 03 6166 7256 The following Radiation Management Plan (RMP) is an example of the type of information expected in your plan for a veterinary radiography practice. You should use the red italic text on the front/cover page and in the right hand column as a guide when writing your own plan and replace the red text with your own words. A plan is required under the Radiation Protection Act 2005 and must be approved by the Director of Public Health. The purpose of a plan is to ensure that the practice of veterinary radiography is conducted safely and in accordance with legislative requirements. Practices are expected to provide general details when describing such items as the practice type and radiation apparatus dealt with, for example: o ‘persons authorised under Schedule 3 Part A of the licence’ under point (a) o ‘radiation apparatus listed in Schedule 1 Part A of the licence’ under point (b) This will avoid the need for you to submit an amended Radiation Management Plan each time you add or remove people or radiation apparatus from your licence. Practices are expected to provide specific details when describing such items as courses of study being undertaken, for example: o ‘Certificate IV Veterinary Nursing’ or ‘No students/trainees at present’ under point (h). A plan may be supported by practice protocols and procedures, which can be referenced in the plan but do not need to be submitted with the plan. A plan should be reviewed by the practice either annually or biannually, and the date for the next review should be recorded on the front/cover page. ___________________________________________________ Sample RMP Veterinary Practice First Issued: 30 June 2006 Last Reviewed: 21 October 2015 Radiation Management Plan For: Dr Penny Roust (applicant for licence to possess/licence holder) holder of licence L000125 to possess radiation apparatus of: Roust Veterinary Services (organisation/company/trading name – as applicable) for the practice of: Veterinary Radiography to be carried out at: 2 Mineral Street, Burnie and at field locations Plan prepared by: Dr Daniel Roust (RSO) Date: 30 April 2015 Contact details: Telephone: 03 6432 1000 Facsimile: 03 6432 1111 Email: roust.vet@burnie.com.au Plan accepted by Dr Penny Roust (applicant/licence holder) who hereby agrees to adhere to all requirements in the plan. Signature: PRoust Date: 30 April 2015 Date for review: 30 April 2017 (date when it is intended that the plan will be reviewed eg in one or two years’ time) 1 Introduction This plan has been prepared in accordance with Regulation 8 of the Radiation Protection Regulations 2006. This plan will ensure the practice of veterinary radiography is conducted as safely as possible and in compliance with the Radiation Protection Act 2005 and the Radiation Protection Regulations 2006. Compliance with this radiation management plan will help ensure the radiation doses to users, other persons involved in the practice, members of the public and the environment are below the prescribed limits and are as low as reasonably achievable. It will also help ensure that the number of people exposed to radiation and the likelihood of unexpected exposure to radiation are minimised. The plan is to be read by everyone in Roust Veterinary Services. Information required by Regulation 8, Radiation Protection Regulations 2006 Details of plan (a) a brief description of the type and scope of the radiation practice Radiography in vet practice – mainly small animals radiographed in designated area of surgery (Certificate of Registration for Place AP/nnn) but occasionally x-ray horses at field locations. Vet surgeons (as per Schedule 3 Part A of the licence) use the x-ray units. (b) a list of the radiation apparatus dealt with As per Schedule 1 Part A of the licence. in the radiation practice (c) an assessment of the potential hazards from the radiation apparatus dealt with in the radiation practice Exposure to radiation from primary x-ray beam; scattered radiation; tube head leakage. (d) details of the environment likely to be exposed to radiation during the radiation practice Vet surgery and adjacent rooms. For field radiography - area within primary beam out to about 10 metres plus area within about two to three metres around x-ray tube. 2 (e) the radiation principles, work practices (including quality-assurance procedures) and equipment (including personal radiation monitors) used to ensure that radiation exposure of persons or the environment is as low as is reasonably achievable during typical types of work carried out within the radiation practice Practice applies the principles for radiation protection outlined in the “Fundamentals for Protection Against Ionizing Radiation” 1 Radiograph taken only if clinically justified; ensure workload specified in the Certificate for Registration for the surgery is not exceeded; collimate beam; Adhere to vet CoP2;work practices that utilize guidance in the Safety Guide for Radiation Protection in Veterinary Medicine (2009) have been developed and are documented, both for radiography in the Xray room and for field radiography. These include restraints used as per the Safety Guide; provision of protective clothing for operators and assistants; use of distance/shielding to minimize the dose to operators. Operators are trained and are authorised on licence; Personal monitor used as area monitor for surgery; another monitor worn by vet for field radiography; QA protocol, based on Annex G of the Safety Guide, has been developed and is available for x-ray imaging systems, including recording and investigating repeat radiographs and any radiograph not in accordance with the imaging request. 1 2 ARPANSA Fundamentals for Protection Against Ionizing Radiation (2014) ARPANSA Code of practice for Radiation Protection in Veterinary Medicine (2009) 3 (f) details of the classes of persons likely to be exposed to radiation during the radiation practice, including (i) children (ii) pregnant women No person under 16 allowed to be in vicinity of x-ray unit while radiography in progress. May assist with radiography but only if wearing protective clothing, standing at least 2 metres from xray tube and if exposure to foetus will not exceed public dose limit. Practice takes fewer than 5 radiographs per week and so this limit will not be exceeded with above protective measures in place. (iii) volunteers in biomedical research Not relevant for this vet practice. (iv) persons exempt from section 13(1) of the Act under Part 10 Students/trainees undertaking the course specified in (h). OR No students/trainees at present. Other persons: Assistants and persons authorised on the licence to ‘use’ the x-ray units. (g) the maximum dose of radiation it is anticipated a person of a class of persons specified in paragraph (f) will receive while the radiation principles, work practices and equipment referred to in paragraph (e) are being used, and the action to be taken if those doses are exceeded Personal monitors should indicate less than 50 µSv per three-month period for a well-run veterinary practice. (h) details of a course of study or training that (i) is being or will be undertaken by a person who is expected to be dealing with a radiation source in the radiation practice (ii) requires, as part of that course of study or training, the person to deal with the radiation source in the radiation practice Veterinary Nurses may undertake Certificate IV Veterinary Nursing (includes radiography) through an approved institution. The practical component of the course is conducted in this practice. OR No students/trainees at present. (i) the name, qualifications and experience of the supervisor of a person referred to in paragraph (h)(i) while undertaking that part Dr Penny Roust, BVSc, registered Veterinarian, 10 years’ experience. OR Will immediately review practices and notify Director of Public Health (DPH) if doses above this level are recorded. 4 of a course of study or training referred to in paragraph (h)(ii) Not applicable at present. (j) the training and information to be provided to persons involved in carrying out the radiation practice In-house radiation safety awareness training for ALL staff; staff assisting with radiography to read CoP, the ‘Fundamentals’ and the National Standard3 and licence conditions and demonstrate an understanding of the requirements in these. (k) the name and contact details of the radiation safety officer (RSO) for the radiation practice Dr Daniel Roust, BVSc Phone: 03 6432 1000 Fax: 03 6432 1111 Email: roust.vet@burnie.com.au 3 National standard for limiting occupational exposure to ionizing radiation [NOHSC:1013(1995)] republished in 2002 by the Chief Executive Officer of ARPANSA 5 (l) a brief description of the role of the radiation safety officer (RSO) Annex A of the Safety Guide RPS17; Section 5 of RPS1; attached ‘Duties of the RSO’. Ensure personal monitoring conducted appropriately and that monitors are stored with the control when not in use. (m) a brief description of the resources available to the radiation safety officer to enable him or her to perform his or her role under the radiation management plan Budget includes funding for personal radiation monitoring, QA program, replacement of protective clothing, compliance testing, and radiation protection training for staff. RSO has ready access to this plan, the licence document, the Certificate of Registration for the place, and all referenced documents. (n) a description of the roles and responsibilities, that are relevant to a dealing with the radiation source in the radiation practice, of all persons authorised by the licence to deal with the radiation apparatus in the radiation practice Licence holder: ensure this plan is implemented. All staff: responsible for following the radiation practices specified in this plan. RSO: see above. Operators named on licence: as per licence conditions. All staff – obey warning signs and written instructions (developed and placed in prominent location in surgery) aimed at minimising their exposure to radiation. All staff - to report to RSO any matter that may compromise radiation safety. (o) the methods used to ensure that the persons referred to in paragraph (n) are aware of their obligations under the Act and the licence Radiation safety awareness training includes provision of information about the licence and its conditions. 6 (p) details of how the radiation apparatus in the radiation practice will be prepared for use, repaired, maintained, transported, stored and disposed of X-ray units to be checked by service engineer for mechanical and electrical safety on an annual basis; compliance checks every four years. Field unit to be packed carefully in transport box to avoid damage during transport and to be set up as per manufacturer’s instructions, on stand, for field use. When no longer required, will seek an amendment to the licence to dispose of an x-ray unit such that it a) is sold, or b) cannot be reassembled for use in accordance with Regulation 19. (q) details of any emergency response plans for the radiation practice including reporting to the Director of Public Health X-ray unit will be switched off/unplugged immediately if aberrant radiation output suspected. DPH will be informed of any malfunction of the x-ray unit that could have resulted in unexpected irradiation of any person or of any situation where person could have been exposed inadvertently. (r) details of procedures that are designed to X-ray unit will be switched off/unplugged immediately minimise the radiation hazard arising from a if aberrant radiation output suspected. radiation incident (s) details of reporting procedures for incidents adversely affecting, or likely to adversely affect (i) equipment used in the radiation practice (ii) the environment (iii) the health or safety of any person Staff are required to report any malfunction of the xray unit/observed damage to unit (e.g. frayed cords, dents in tube casing) to RSO immediately. Any other incident also to be reported to RSO who will take immediate action and pass on information to Dr Penny Roust (licence holder) for any further investigation and action, including reporting to the DPH. (t) details of record-keeping requirements including details of the records that will be kept of movement of any mobile radiation source in the radiation practice Records of all radiographs will be maintained for at least seven years and will indicate the operator, exposure factors, patient and view. Record of disposal of unit will be maintained as per Regulation 26, Radiation Protection Regulations 2006. (u) details of the use of radiation warning signs and labels in the radiation practice. Warning labels on the x-ray units and on surgery entrances, as per CoP and Certificate of Registration for the place. Referenced documents: 7 CoP: ARPANSA Code of Practice and Safety Guide for Radiation Protection in Veterinary Medicine RPS 17 July 2009 RPS1: National standard for limiting occupational exposure to ionizing radiation [NOHSC:1013(1995)] republished in 2002 by the Chief Executive Officer of ARPANSA Fundamentals: ARPANSA Fundamentals for Protection Against Ionising Radiation (2014) Radiation Protection Regulations 2006 Radiation Protection Act 2005 Attached details: Duties of the RSO 8 Duties of the RSO: The RSO will: a) supervise the radiation protection aspects of the radiation practice that are specified in the radiation management plan b) operate and interpret the readings from radiation monitoring equipment that is required for the radiation practice c) understand the precautions (including the use of protective clothing and equipment) to be taken in carrying out the radiation practice d) understand the extent to which the precautions referred to in paragraph (c) will restrict exposure to radiation e) know the actions required to carry out the emergency procedures specified in the radiation management plan f) help the holder of the licence implement the employer’s duties specified in Chapter 5 of the National standard for limiting occupational exposure to ionizing radiation [NOHSC:1013(1995)] republished in 2002 by the chief executive officer of ARPANSA g) carry out the duties recommended for a radiation safety officer in Safety Guide for Radiation Protection in Veterinary Medicine RPS 17 July 2009. 9