DOE federal regulations for occupational radiation protection (10 CFR 835) require that radiological training commensurate with the hazards in the area and the required controls be completed before personnel:
- Are permitted unescorted access to controlled areas
- Receive occupational dose during access to controlled areas
- Are permitted unescorted access to radiological areas
- Perform unescorted assignments as a radiological worker
LBNL policy also implements the 10 CFR 835 requirement that radiological training be renewed at intervals not to exceed 24 months.
At LBNL, General Employee Radiological Training (or GERT, EHS 0470) satisfies the minimum training requirement for access to radiologically controlled areas and to receive occupational dose. If your GERT training expires, the site access control system will not allow you onto the main LBNL site outside of normal working hours and your access through card key controlled doors into controlled areas will be inactivated. Anyone accessing a controlled area while their GERT is expired violates Laboratory policy and federal regulations.
Additional radiological training is required to access radiological areas or to perform radiological work. This additional training can be in the form of (either individually or in combination): radiation worker (EHS 0471 or 0473), on-the-job (OJT), or other specific radiological training. When such required training expires, personnel are no longer permitted unescorted access to radiological areas or to perform unescorted assignments as radiological workers.
Radiation worker training (EHS 0471 or 473) satisfies the GERT training requirement. All other radiological training at LBNL (e.g. OJT, X-Ray, etc.) is built upon GERT (i.e. one has to have GERT as the base training). If your GERT expires, the privileges afforded by the other training are also invalidated.
Training compliance takes on additional significance if the employee is also the Principal Investigator (PI) for a radiological work authorization. Radiological work authorizations are issued on the premise that a fully qualified person (the PI or PI Designee) assumes the roles and responsibilities to ensure work is performed within the scope authorized and that all required controls are in place. If the PI’s training lapses, they are no longer fully qualified, thus negating said premise. Unless there is a PI Designee whose training is current, the work authorization will be inactivated and no authorized work can be performed.
The Radiation Protection Group (RPG) monitors the status of radiological training, communicates with the parties involved, and takes actions necessary to protect the individual and the Laboratory from violations, fines, and other potential legal action. However, the ultimate responsibility for training compliance remains with each worker and their line management. All workers receive notifications of their upcoming retraining requirement. It is imperative that they heed the notifications and take actions. If scheduled events or activities preclude timely completion of required training, contact the RPG as soon as possible. They may be able to help take actions to prevent noncompliance and/or work disruption.
If you have any questions about these requirements please contact David Kestell (486-7157).
