USDA has a Location Radiation Protection Officer (LRPO) program to provide for radiation safety oversight at its field locations. An LRPO must be designated at locations that have more than one Permit Holder. However to ensure an effective radiation safety program all locations are encouraged to designate an LRPO. The LRPO cannot be one of the Permit Holders at the location, except that an LRPO will be issued an LRPO Permit for waste management and emergency activities. There is an LRPO representative on the Radiation Safety Committee.
The LRPO assists local management in assessing compliance with radiation safety program requirements. The LRPO duties and responsibilities include assuring that radioactive materials are used in a safe manner and that program deficiencies and items of non-compliance are quickly and effectively resolved. In order to accomplish this, local management must provide the LRPO with sufficient time, commitment, and independence.
The LRPO will be subject to specific RSD requirements and obligations through the LRPO Permit. The LRPO will also be subject to guidelines and expectations which will be implemented at the location level. These guidelines may vary according to the number and kinds of Permits at a location but may include general radiation safety program guidance to managers and users as well as specific guidance for new Permit Holders and guidance on terminating Permits when Permit Holders leave.
The LRPO additionally does the following things:
For locations with several isotope Permit Holders, the LRPO coordinates survey meter calibrations to assure that all survey meters are calibrated at the required frequency.
Location management has a significant responsibility in maintaining compliance with the USDA Radiation Safety Program. Local management chooses the LRPO, which RSD usually approves. The LRPO may be a safety person such as an environmental safety specialist, or an industrial hygienist. The LRPO, may also be a primary investigating scientist or technician who once had a Permit in USDA, or who has had previous experience working with radioactive material. The LRPO cannot be one of the Permit Holders at the location.
LRPO responsibilities may be ancillary to another position. However, some locations may choose to have a full time LRPO. The LRPO will usually have a Permit issued by RSD. However, for some locations with a single Permit Holder, with a small scale Permit, the LRPO may not be required to have a Permit. Depending on the type of materials used and the Agency's management structure, the LRPO designated for each location may work at the location or at a State or regional office.
LRPOs must meet the training and experience requirements for a Permit Holder of the types of material used at their locations. The LRPO should be familiar with the RSD website, the “comprehensive guidance and requirements” documents, and all RSD requirements and obligations.
The LRPO facilitates and reviews permit applications, to assure that the application is complete and has all of the required management approval signatures. For unsealed isotopes, a general research protocol is required for routine program activities. If the scope of research involves human use studies, large animal studies, or field studies, applicants are encouraged to discuss these activities with RSD prior to submitting an application, since there may be additional requirements.
Based on the research or program activities and requirements for the rad-types, various combinations of forms must be submitted to the Radiation Safety Division. The LRPO can help decide how to apply for a Permit. The LRPO also facilitates Permit termination or transition if a Permit Holder leaves.
The LRPO coordinates radiation safety training for users of radioactive material and for ancillary staff and maintains employee training documents. This may include a rranging with contractors to provide initial and annual refresher radiation safety training.
The LRPO conducts an initial radiation safety orientation with each new Permit Holder and associate user, to describe the radiation safety program. Orientation training topics that the LRPO needs to cover are described in the Comprehensive Guidance and Requirements for radiation types used in USDA.
The Radiation Safety Division conducts periodic field inspections at each location where there are Permit Holders. These inspections are usually done by appointment, with the inspector contacting the LRPO about the inspection. The LRPO works with the inspector, helping to arrange the appointment for the inspection, facilitating the inspection, and acting as the location representative.
The Nuclear Regulatory Commission (NRC) also conducts inspections of USDA locations. NRC inspections are usually unannounced, so that the LRPO may not be present during an NRC inspection, and should arrange ahead of time for an alternate Permit Holder or Associate User to meet an unexpected NRC inspector. The LRPO is additionally responsible for maintaining the results of NRC and RSD inspections.
The LRPO is responsible for performing the annual radiation safety program audit for the location, under RSD supervision. This includes reviewing each Permit Holder to determine whether copies of required reports are maintained, materials are used only in approved areas, laboratories are properly posted, appropriate documents are posted or are available, and radioactive material is secured to prevent unauthorized removal. The LRPO advises management on appropriate actions to correct program deficiencies, where necessary.
The LRPO is responsible for identifying unsafe practices and instances of non-compliance, to be brought to the attention of location management and RSD. For unsealed isotope Permit Holders, this could mean failure to maintain security of isotopes, or failure to keep up with required lab surveys. For gauge Permit Holders, this could mean failure to maintain the log book or failure to keep up with leak tests.
For locations with isotope Permit Holders, the LRPO coordinates radiation waste management and disposal functions. The LRPO involvement depends on the number of isotope permits and the amount of waste generated. The LRPO keeps track of radioactive waste disposal methods used by each Permit Holder and assures accurate radioactive waste labeling and security of materials. The LRPO coordinates radioactive waste shipments and maintains shipment manifests. For locations approved to incinerate radioactive waste, the LRPO coordinates incineration operations and reviews ash evaluations and associated records to assure that procedures established for the site are followed. The LRPO may also help determine effluent limits for radioactive waste disposed of through the sanitary sewerage system or for unrestricted release to air and water, and also maintains effluent disposal reports;
The LRPO assists facility management in responding to radiological emergencies and unusual events and coordinating technical assistance through the RSD and other responders. The LRPO will contact RSD immediately for any unusual incident involving radioactive materials such as:
After normal business hours or when the situation demands, contact the USDA Operations Center at 202-720-5711 or 877-677-2369 and provide them with information about your emergency; they will contact RSD and make sure someone responds quickly.
For immediate, on-site radiation safety assistance, contact your State Radiation Protection Office through the following link: Agreement States .
If a Permit Holder leaves USDA suddenly, without terminating the Permit, the Permit will remain active and operational in that person’s name, until all of the termination conditions have been met. If that is the case, it is important for local management and LRPO to expedite the termination of the Permit to avoid being out of compliance with the USDA Radiation Safety Program. Until this can be accomplished, the LRPO is responsible for the Permit.
The LRPO notifies the RSD when a Permit Holder intends to stop using radioactive materials to facilitate termination of the user permit. For Permit Holders who are leaving the location, the LRPO coordinates technical and administrative requirements for terminating the Permit, or transferring it to a new Permit Holder.