The University of Chicago

In order for any institution to use radioactive material, licenses have to be obtained from state and/or federal agencies. License applications include proposed methods that will ensure compliance with the applicable regulations. If the agencies are satisfied with these procedures, a license is granted for a period of one to five years. During this period, the agencies make one or more on-site inspections.

Copies of the University's Illinois Emergency Management Agency (IEMA), Division of Nuclear Safety licenses, and related Federal and State Regulations are available for reference in the Office of Radiation Safety (ORS) during normal working hours. Federal regulations are also available in the Joseph Regenstein Library.

This manual is designed to alert users of their responsibilities under licenses issued to the University and to outline procedures and techniques which should be used to minimize radiation exposure and to ensure compliance with applicable regulations and license conditions.

The full cooperation of every University user of radioactive material is necessary in order for all users to benefit from use of this indispensable research and diagnostic tool; oversight by only one individual can jeopardize an entire license and adversely affect all research that depends on isotopes held under that license. In addition, during an inspection by a federal or state agency all users shall afford the agency representative the opportunity to inspect such materials, machines, activities, facilities, premises and records as the agency representative determines are necessary to establish compliance with the requirements of the license and regulations.

The term "must" and "shall" in this manual are used to describe procedures that are required directly or indirectly by license conditions or regulations. The term "should" is used to describe procedures that are recommended to reduce the potential for radiation exposure but not required by license conditions or regulations.

A. Application Procedure

Application for Non-Human Use of Radioactive Material

To acquire radioactive material a new applicant must complete an "Application for Non-Human Use of Radioactive Material". The completed application must be returned to the Office of Radiation Safety. Once approved by the University Radiation Safety Committee the application will be active for two years. The following forms are required for authorization to possess and use radioactive materials (These forms are available on the ORS website).

1. Application for Non-Human Use of Radioactive Material (ORS Form A1);

2. PI Statement of Training and Experience (ORS Form A4);

3. Account Authorization Form (ORS Form A5); and

4. New User Amendment and Training Certification Form (ORS Form A3)

Applications from new users, new uses, or for uses involving new procedures or facilities not previously approved for radioisotope work must be submitted well before the date by which the material is needed. Applications require approval by the University Radiation Safety Committee. Nominal time required for Radiation Safety Committee review and approval of applications is approximately three to four weeks.

Please note: If your application requires submission of a license amendment request to the IEMA, Division of Nuclear Safety or another governmental agency, the application will be placed in a "pending status" until the University's license amendment is obtained. These types of license amendments generally require several months for approval.

The application procedures outlined in this manual are only for obtaining and retaining approval from the University of Chicago Radiation Safety Committee to use radioactive material under radioactive material licenses issued to the University and do not apply to procedures that may be required by other University committees.

Applications for radioactive material studies involving animals must be obtained from the Institutional Animal Care Use Committee (IACUC). Complete an Animal Care and Use Protocol application and submit to the Office of Research Services, Regulatory Compliance Administrator.

Approval for the use of radioactive materials in humans for research purposes must be obtained from the Radioisotope Drug Research Advisory Committee (RADRAC). Complete a RADRAC Application and submit to the Office of Research Services, Regulatory Compliance Administrator.

Renewal Applications

Each principal investigator is required to file a renewal application every two years to continue their authorized use of radioactive material. The Office of Radiation Safety will send each authorized principal investigator instructions on the renewal process approximately one month prior to the expiration date of their protocol. Forms are available on the Office of Radiation Safety website.

Amendments

Principal Investigators that have been granted approval for use of radioactive material may need to amend their authorization. Amendments are considered changes in laboratory locations, radiochemicals, radiochemical order limits, proposed uses, and laboratory personnel who may work with radioactive material. Forms are available on the Office of Radiation Safety website.

The following procedures are to be conducted to amend an authorization:

Notifications for room changes (adding new lab or discontinuing use in a lab)

Radioactive material may only be used in laboratories and cold rooms approved by the Office of Radiation Safety under the approval by University Radiation Safety Committee. In order to amend your areas of use, submit an amendment application form (ORS Form A2) listing the change (building and room number) and the effective date of this change to the Office of Radiation Safety. Please note that the amendment must be approved prior to using or storing radioactive material in the new location. If the room change involves the termination of radioactive material work in that lab, the Office of Radiation Safety will perform a closeout survey certifying that no radiological hazards exist in the space.

Please note: If your lab is moving or leaving the University, the Office of Radiation Safety requires advance notification (1 week) to schedule the surveys, radwaste removal, and cancellation of all radiation safety related services. Call the Office of Radiation Safety and submit an email to the Associate Director and/or Radiation Safety Officer. Surveys of lab equipment used in radioactive material experiments are required prior to being packaged for moving. In addition, a laboratory close-out survey is conducted after the movers have removed all equipment.

Notification for changes in possession limits and changes in physical or chemical form.

Submit an amendment application (ORS Form A2) listing the change to the Office of Radiation Safety for possession limit increases, physical or chemical form changes of radioactive material presently listed on your protocol.

In order to add new radiochemicals the Principal Investigator must complete and submit an "Application for Non-Human Use of Radioactive Material" (ORS Form A1) to the Office of Radiation Safety.

Adding laboratory personnel who will work with radioactive material.

Laboratory personnel who work with radioactive material are required to be listed on the application. In order to update the laboratory personnel list, a "New User Amendment and Training Certification" form must be submitted to the Office of Radiation Safety. All new radioactive material (RAM) users must attend the RAM user training provided weekly by the Office of Radiation Safety.

In addition, labs are required to update their Radiation Safety Training Certificate form or list of users (posted in their lab) reflecting the addition of lab personnel.

Adding or modifying survey instruments

In order to add a new survey instrument, add a new probe, or discontinue use of a survey instrument, you are to submit a memo or email outlining the change including the instrument's model and serial number. A member of the Radiation Safety staff will contact the lab designee to conduct the change.

Please note: If you have purchased a new instrument, the Office of Radiation Safety will affix a sealed source to the instrument (if a source was not purchased with the instrument) to be used for the instrument operational checks. A copy of the manufacturer’s calibration certificate must be submitted to the Office of Radiation Safety. If you are unable to locate the calibration certificate, the Office of Radiation Safety will be required to recalibrate the instrument before it can be used in the laboratory.

B. Radioactive Material Ordering Procedure

Procurement Policy:

The purchase of radioactive materials including both licensed and license-exempt quantities is handled through the Office of Radiation Safety (ORS). Only principal investigators with an approved* protocol will be allowed to order radioactive materials. The ordering will be limited to the isotopes, chemical forms, and maximum activity per month as listed in the protocol application.

Anyone found not following the procurement policy risks suspension of their protocol.

Only radioactive material items may be included on a radioactive material order. If non-radioactive material items are on a radioactive material order the order will be rejected by ORS. Anyone found not following the proper ordering procedures risk having their ordering privileges denied and suspension of the protocol.

All radioactive material orders must be placed through the Buysite Procurement system following the procedures above.

1. Researchers are only allowed to order radioactive material listed on their approved radioactive material protocol. If you need a copy of the protocol application, please call the ORS at 2-6299.

2. When placing a radioactive material order you MUST check the “Radioisotope order” box. It is the third item down in the middle column on the active cart screen.

3. When entering a radioactive material order please indicate the following on the order:

a. The shipping address must be:

Receiving Dock

The University of Chicago

Office of Radiation Safety

5835 South Cottage Grove Avenue

Chicago, Illinois 60637

b. The billing address must be:

Central Procurement Services

1225 East 60th Street

Mott 125

Chicago, Illinois 60637

c. Your Profile (Buyer Info): Along with your name include the Principal Investigator name and HP10 # (e.g. James Marsicek/Dr. John Doe, HP10# 3937). This information (Principal Investigator and protocol number – HP10#) will assist ORS staff to approve your orders more quickly.

d. Product Information: Indicate the isotope, catalog number, product description, number of units, and activity (mCi or µCi). If requesting a product from the Fresh Lot, please specify in the “Note to the Supplier”.

e. Workflow: After creating your order and submitting it, it will be sent to the Account Administrator (AA) for approval. Once approved by the AA the order will be sent to the Office of Radiation Safety (ORS). ORS approvers will review the order, compare the order to the approved protocol and if approved, will place the order from the vendor.

f. All orders approved by the Account Administrator by 12:00 pm (Noon) will be reviewed and approved the same day by the Office of Radiation Safety. Orders received after 12:00 p.m. may not be reviewed and approved until the next working day.

Please note: If your protocol (application) for radioactive material use has expired, we will not be able to place your order. If you are not sure of the expiration date, please call our office.

If you should have any questions regarding any aspects of this process, please feel free to contact the Office of Radiation Safety at 2-6299.

*The definition of an approved protocol is one that is approved by the University Of Chicago Radiation Safety Committee that has no outstanding violations that would warrant a suspension.

C. Radioactive Material Accountability

1. Radionuclide Receipt and Usage

The Office of Radiation Safety will issue a Radionuclide Package Receipt and Disposal Record with each radioactive material order placed by the principal investigator. The log incorporates receipt, usage and disposal information for radioactive material orders. This documentation process is what is called the “Cradle-To-Grave” concept for tracking radioactive material from the time the material is received on campus to the time of its disposal.

Whenever any radioactive material is removed from the vial the radioactive material user must record the date, the volume of material removed, approximate percent of activity disposed as radioactive waste, manifest numbers of the waste containers, and his/her initials.

When the contents of the stock vial are exhausted or no further aliquots will be removed, lab personnel must enter the residual or remaining activity and the disposal box manifest number of the corresponding stock vial on the Package Receipt and Disposal record. Each user must also record disposal container manifest numbers for waste generated on the usage log.

A copy of the completed Package Receipt and Disposal record must be submitted to the Office of Radiation Safety. Items listed on the radioactive material inventory will not be deleted until the completed Package Receipt and Disposal record is submitted. Receipt and Disposal records submitted to the Office of Radiation Safety with missing information will not be removed from the PI inventory until the missing information has been completed.

2. Radioactive Material Inventory

Inventory forms are sent periodically (approximately quarterly) to principal investigators listing the radioactive material orders outstanding against their applications. The research laboratory must conduct a physical inventory of items listed on the inventory list to identify whether they are present and still in use or have been disposed. The inventory form must be completed and returned to the Office of Radiation Safety by the due date (approximately fifteen working days from the notice letter). Additional orders will not be placed if the inventory form is not returned within the prescribed time. The University Radiation Safety Committee has authorized the Office of Radiation Safety to physically perform the inventory for principal investigators that fail to return their inventory. These inventory records are required by State regulations and are maintained by the Office of Radiation Safety for review by regulatory inspectors.

D. Transferring Radioactive Material

In cases where the radioactive material is to be acquired from a radioisotope user at the University of Chicago, the person who is to be the supplier PI must verify that the recipient PI is authorized to receive the radioactive material. The supplier PI must contact the Office of Radiation Safety to verify that the recipient PI has an approved application on file. Approval must be obtained from the Office of Radiation Safety prior to the transfer of radioactive material.

(Please note: If the recipient received radioactive material and was not authorized to possess the material, the University would be in non-compliance with the radioactive material license issued by IEMA, Division of Nuclear Safety. In addition, this will jeopardize the supplier Principal Investigators protocol privileges.)

Laboratories receiving radioactive material as a loan or gift are required to have an approved application on file with the Office of Radiation Safety and must PROMPTLY notify Radiation Safety of the receipt of such a loan or gift.

Radioactive material being shipped outside the University must be approved by the Office of Radiation Safety. To ship radioactive material to another institution, the U of C, Office of Radiation Safety must obtain authorization from the recipient institution's Radiation Safety Office and a copy of their institutions radioactive material license. Please notify our office in advance of the shipping date, so that our staff can complete the necessary shipping documents and obtain the necessary licensing documents and packaging materials.

Please note: The principal investigator or his/her staff must not transport radioactive materials in their own vehicles. All shipments of radioactive material must be completed by the Office of Radiation Safety staff trained in the shipping regulations issued by the U.S. Department of Transportation (DOT) and the International Air Transportation Association (IATA)

If you are shipping radioactive material to another institution, you must provide the Office of Radiation Safety with the following information well in advance of shipping the radioactive material:

1. Shipment Address of the institution;

2. Telephone Number and Contact Name of end user;

3. Radiation Safety Officer name and contact number;

4. The isotope, chemical and physical form of the radioactive material;

5. Shipment method, your shipper account number (e.g. FedX number) and all packaging materials; and

6. Projected activity at time of shipment and shipping date.

E. Occupational Exposure

1. Limits

MAXIMUM PERMISSIBLE DOSE LIMITS FOR RADIATION WORKERS	ADULT WORKERS	<18 YEARS OLD
Whole Body (Total Effective Dose Equivalent) Sum of Internal & External Exposure	5 Rem/Year	0.5 Rem/Year
Any Individual Organ or Tissue Other than lens of Eye (Total Organ Dose Equivalent) Sum of Internal & External Exposure	50 Rem/Year	5 Rem/Year
Lens of the Eye	15 Rem/Year	1.5 Rem/Year
Skin of Whole Body	50 Rem/Year	5 Rem/Year
Extremities	50 Rem/Year	5 Rem/Year

2. Pregnant Radiation Workers

Declared pregnant employees radiation exposure limit: 0.5 rem during entire pregnancy.

Pregnant employees have the option to voluntarily declare their pregnancy, in writing, to their supervisor and the Office of Radiation Safety. Declaration of the pregnancy allows the radiation exposure to the fetus to be closely monitored and additional precautions may be taken. If you should have any questions, please contact the Office of Radiation Safety.

3. Dosimeters (Radiation Badges) To Monitor Exposure to Radiation

All persons whose work is associated with radiation that could result in exposure above 10% of the above limits must wear radiation monitoring badges (5% for persons under 18 years of age). Whole body dosimeters and extremity badges are issued for a one to two month wear cycle and are used to monitor exposure from high-energy beta, neutron, and gamma-ray sources. Whole body dosimeter and ring badges do not respond well to weak beta radiation from H-3 and C-14. Workers who use H-3 or C-14 or less than 1 mCi a month of S-35 and/or P-32 are not required to wear a dosimeter. Workers that use 10 mCi or more of P-32 or other high-energy beta emitters at a time or use more than 1 mCi of a gamma-ray source are required to wear a whole-body dosimeter and ring badge.

Requests for starting and canceling radiation badge service must be made by completing a request card available from the Office of Radiation Safety. Since badges have to be ordered and/or discontinued by Radiation Safety several weeks in advance, request cards should be received in M031A no later than the tenth of the month or date specified by the Office of Radiation Safety for the change to become effective for the next wear period.

All dosimeters (whole body and ring badges) for a new wear period are distributed by Radiation Safety near the end of the previous wear period. Old badges from the previous wear period must be returned to the place of delivery by the 10^th day of the month of the current (new) badge wear period.

The whole body dosimeter should be worn on the area of the whole body (from the knee up and elbow up) most likely to receive the highest exposure (e.g. on the upper chest area) with the identification sticker facing forward. If lead aprons are worn, the badge should be clipped to the shirt collar or to the outside of the top of the lead apron to measure exposure to the eyes. Supplemental badges, if issued, may be worn under the lead apron but readings obtained from such badges do not accurately measure exposure to the eyes or thyroid.

The Office of Radiation Safety will assign a temporary badge to you if you lost your dosimeter (radiation badge). Contact the Office of Radiation Safety as soon as you know the dosimeter is lost.

Ring badges shall be worn on the dominant hand with the label facing in the direction that your hand will receive the highest radiation exposure. This badge must be protected from contamination; therefore, it must be worn under gloves when you are working with radioactive material.

Exposure reports are reviewed by the Office of Radiation Safety. Individuals and their supervisors are notified in writing of any excessive exposures and are required to describe the cause and corrective steps that have been taken, or are planned to be taken, to prevent a recurrence of the exposure. The completed and signed notification must be returned to the Office of Radiation Safety within ten working days.

Dosimetry records are maintained by the Office of Radiation Safety. Wearers are encouraged to request their radiation exposure readings. Written requests for exposure information should be directed to the Office of Radiation Safety. Annual reports are submitted to departments for distribution to monitored individuals within the department.

F. Use of Radioactive Material

1. Training

The principal investigator is responsible for ensuring that all radioactive material (RAM) users and laboratory designees within his/her laboratory are trained on the safe use of radioactive material, initially and annually thereafter. In addition, all laboratory non-RAM users or non-laboratory personnel that may enter into an area where radioactive material is used or stored are required to receive radiation safety awareness training, initially and annually thereafter.

The radiation safety training for personnel is divided into three categories of workers (RAM users and non-RAM users). The following will define the initial and annual radiation safety training requirements for both worker categories.

a. Non-RAM Users and Non-Laboratory Personnel Awareness Training

Examples of non-RAM users and non-laboratory personnel are: laboratory workers who do not use or handle radioactive materials, administrative personnel, and facilities services personnel, to name a few.

1) Initial Training Requirement

All individuals entering a radioactive material laboratory must complete

radiation safety awareness training. These individuals may complete

this training requirement by reviewing the Radiation Safety Awareness

Training Module on the ORS website at: http://safety.uchicago.edu/radiation/uofcinfo/Training/Training_Home_Page.htm

Each individual reviewing the module shall complete the statement of initial training after reviewing the module. A copy of the statement of training shall be submitted to ORS.

2) Annual Refresher Training Requirement

All non-RAM users must receive annual refresher training for radiation

safety. This training may be completed in the same manner as C.1. above.

b. RAM User Training (Includes PI and RAM Users)

1) Initial Training Requirement

b) All new & current employees (including new Principal Investigators applying for a radioactive material protocol) being added as RAM users to a protocol must attend the Office of Radiation Safety training course for RAM users prior to any use of radioactive material. If a Principal Investigator believes it would benefit his/her staff (current RAM users), they are more than welcome to register and attend.

Please note: All new Principal Investigators applying for a radioactive material protocol must attend the RAM user training course. This requirement is to ensure he/she is informed of the University requirements for maintaining compliance with the University of Chicago license conditions and the IEMA, Division of Nuclear Safety regulations.

c) The ORS RAM User training course is offered weekly. Call ORS to obtain the course schedule.

d) Call ORS at 2-6299 to register.

e) Course duration is approximately 2 hours.

e) Knowledge assessment will be provided to attendee’s, so ORS can determine the effectiveness of the information provided and ensure all attendee’s understand the information.

f) Training certificates will be provided to each RAM user after attending the training.

g) PI submittal of the New User Amendment and Training Certification form to ORS (fax no. 2-4008, mail MC2106 or deliver to AMB M-031A) is required to add a RAM user to the protocol!

2) Annual Refresher Training Requirement

a) All RAM users (including PI’s) must complete the annual training requirement by one of the following methods:

· Attend the RAM user training course presented by ORS; or

· Review the University Radiation Protection Manual and complete the knowledge assessment with signature.

b) The annual refresher radiation safety training form must be updated yearly and must include the signatures of all RAM users in the lab, the signature of the PI. The completed training form must be submitted to ORS (faxed, mailed or delivered), to update and maintain a current protocol. In addition the annual training form must be posted in at least one laboratory.

c. Laboratory Designee Training (Includes PI, if designated at Lab Designee)

Principal Investigators are required to appoint two staff members as their laboratory designees (one Primary and one Secondary) to assist them with the radiation safety oversight in the laboratory and to act as a point of contact for the Office of Radiation Safety. Each lab designee is required to attend the RAM user and laboratory designee training courses prior to their laboratory's use of radioactive material or prior to the previous lab designees departure.

1) Initial Training Requirement

a) Each individual assigned the lab designee responsibilities must first attend the RAM user training course and then the laboratory designee training course presented by ORS.

b) The RAM user course is presented weekly as noted under the RAM user training requirements and the lab designee course is presented once a month. The lab designee course duration is approximately 90 minutes.

c) Knowledge assessment will be provided, so ORS can determine the effectiveness of the information provided and ensure the attendee’s understand the information.

d) Training certificates will be provided to each laboratory designee after attending the training.

2) Annual Refresher Training Requirement

a) The laboratory designee must complete annual refresher training. These individuals are not required to attend the lab designee training course to complete their annual training unless the ORS laboratory audit and/or survey process identifies non-compliance with radiation safety practices and procedures in the laboratory.

b) The annual training for laboratory designee’s can be completed by one of the following methods:

· Complete the one of the RAM user refresher training methods as noted above; or

· Attend the lab designee course again.

Training Reminders:

All individuals in the laboratory as well as non-laboratory personnel must undergo training once a year (annual refresher training). Annually, the ORS will notify the principal investigators of the refresher training requirement and provide the training tools needed to meet the training requirement.

Refresher training for all the RAM users list under each Principal Investigator must be documented on the “Annual Refresher Radiation Safety Training Certification" form and be on file with the Radiation Safety Office. In addition this form must be posted in the laboratory.

2. Facilities

It is each principal investigator's responsibility to provide adequate shielding and monitoring instruments for use with their radioactive material and to ensure compliance with the regulations and the appropriate radiation safety practices will be met by anyone working with their material. In addition, it is each applicant's responsibility to ensure they have access to a functional fume hood for use of volatile radioactive material.

The Office of Radiation Safety must be notified when fume hoods used in radioactive material experiments become nonfunctional. In addition, the Office of Radiation Safety must be notified prior to service calls for clogged sinks, nonfunctioning hoods, or exhaust system filter changes.

3. Survey Requirements

Surveying for contamination must be performed by the RAM user during and after each experiment or use. Particular attention should be directed to the hands, shoe soles, lab coats, working surfaces, equipment used, waste storage areas/containers, radioactive material storage units (refrigerators, freezers, etc.), and the floor in the working area.

a. Proper Survey for Detection of Specific Isotope Used

1) Users working with H-3 must perform wipe tests to survey for contamination and use a liquid scintillation counter to analyze the wipe tests. The following procedure must be followed when performing the wipe tests:

· Wear appropriate personal protective equipment (e.g. gloves, lab coat);

· Use small pieces of absorbent material (Kimwipe, filter paper, paper towel, cotton-tipped applicator) for wiping the area to be surveyed;

· An area of 100 cm² or more should be wiped for each area to be surveyed;

· Wipe all potentially contaminated areas in an S-shaped pattern;

· Place each wipe sample in a vial (one sample per vial) and add the appropriate type and volume of cocktail to each vial (4 ml for a 5 ml vial);

· Prepare a “blank wipe” sample to determine the background reading;

· Each sample (including the background sample) must be counted for 1 minute;

· Use the LSC protocol that is programmed for detection of the appropriate isotope energies.

2) Radioactive material users working with C-14, Na-22, P-32, P-33, S-35, Cl-36, Ca-45, Cr-51, Zn-65, Rb-86, Nb-95, Tc-99m, or I-123 must survey with a thin-end window or pancake Geiger- Müeller (G-M) detector. See item F.4.e. under the survey instruments section of this manual for effective use of the survey instrument. Remember to complete the battery test and operational check prior to use per the instructions under item F.4 of this manual.

3) Radioactive material users working with I-125 must survey with a sodium iodide scintillation detector. See item 4.e. under the survey instruments section of this manual for effective use of the survey instrument. Remember to complete the battery test and operational check prior to use per the instructions under item F.4 of this manual.

b. Survey Documentation

1) Frequency for Usage of 250 µCi per month or more: Each laboratory is required to document a survey once per week unless radioactive material has not been used since the last documented survey. This statement means that a survey is only required to be documented weekly during the times you use the material. (For example: If the survey was documented on Friday and someone used material on Saturday, you need to document a survey the following week, even if there was no more material used the next week.) Therefore, a survey is not required based solely upon items being on the laboratory inventory. The use of any isotope requires a documented survey for the corresponding week.

2) Frequency for Usage of Less Than 250 µCi per month: The laboratory possessing and using less than 250 µCi per month may apply for a monthly survey frequency that must be approved by Radiation Safety. If a laboratory is not approved for a monthly survey frequency, they must document surveys as indicated in 3.b.1).

3) Standardized Survey Forms: Surveys must be documented with one of the standardized survey forms provided by the Office of Radiation Safety. The entries on either survey form must show the areas surveyed, the date of the survey, the radiation measurements, the instrument used, decontamination results, and the initials of the person or persons performing the survey. The standardized survey forms are posted on the Radiation Safety website: http://safety.uchicago.edu/radiation/uofcinfo/Forms/radiation_safety_forms.htm

The standardized survey form provides some brief instructions and includes a check box to signify the weeks you had no usage since the last survey. It is recommended that the laboratory staff check the Package Receipt and Disposal records each week to determine if radioactive material was used during the week (since the last survey) and to determine whether or not a documented survey is required. There is a form on the ORS website to assist in conducting and documenting a weekly check of radioactive material usage in the laboratory.

c. Decontamination Guidelines for Removable Contamination

Researchers are required to conduct decontamination procedures when removable contamination exceeds the action levels listed below. Removable contamination is defined as radioactivity that can be transferred from a surface to a smear paper by rubbing with moderate pressure.

1) Wipe test greater than 400 cpm

2) Removable contamination above the survey instrument background exposure reading for GM and NaI probes (see 4.e for average background readings).

After decontamination has been completed the area where the contamination was present must be resurveyed following the appropriate procedure to ensure the area is properly decontaminated. The contamination incident must be properly documented on the survey report.

d. Shielding Requirements for Fixed Contamination and Elevated Exposure Rates

Researchers are required to ensure exposure rates in occupied areas are maintained as low as reasonable achievable. Therefore, appropriate shielding must be used to decrease exposure rates in these areas below the action levels listed below. Fixed contamination is defined as radioactivity remaining on a surface after repeated decontamination attempts fail to significantly reduce the contamination level. You may expect to find elevated exposure rates around your waste storage areas, stock and sample storage areas, and work areas.

1) GM survey instrument reading >0.25 mR/hr or 600 cpm, or 6 cps for Mini-Monitors and Rad-Monitors that read in cps

2) NaI survey instrument reading >1000 cpm

After shielding of the fixed contamination or area of elevated exposure rates the area must be resurveyed to ensure the shielding has been properly positioned and sufficient shielding thickness was used. The actions taken to reduce the exposure rate must be properly documented on the survey report.

4. Survey Instruments

Users working with C-14, Na-22, P-32, P-33, S-35, Cl-36, Ca-45, Cr-51, Zn-65, Rb-86, Nb-95, Tc-99m, or I-123 must have access to a survey instrument with a thin-end window or pancake Geiger-Müeller(G-M) detector. Users working with I-125 must have access to a survey instrument with a sodium iodide scintillation detector. Principal investigators using 1 mCi or more of C-14, Na-22, P-32, P-33, S-35, Cl-36, Ca-45, Cr-51, Zn-65, Rb-86, Nb-95, Tc-99m, or I-123 at any one time are required to have a working survey instrument with a thin-end window or pancake Geiger-Mueller probe in the laboratory at all times. Principal investigators using 1 mCi or more of I-125 at any one time are required to have a working survey instrument with a low energy sodium iodide crystal probe in the laboratory at all times.

a. Survey Instrument Calibration

Survey instruments in use must be returned to the Office of Radiation Safety for recalibration on an annual basis. If needed, ORS will send the survey instrument to the manufacturer for calibration.

If you have purchased a new instrument, the Office of Radiation Safety must be notified. The Office of Radiation Safety will affix a sealed source to the new instrument (if a source was not purchased with the instrument) to be used for the instrument operational checks. A copy of the manufacturer’s calibration certificate must be submitted to the Office of Radiation Safety. If you are unable to locate the calibration certificate, the Office of Radiation Safety will be required to recalibrate the instrument before it can be used in the laboratory.

b. Survey Instrument Repairs

Minor repairs of malfunctioning survey instruments can be made by Radiation Safety for some instruments in wide use. Instruments requiring major repairs or instruments for which Radiation Safety does not maintain parts should be returned to the manufacturer for repair and recalibration. A copy of the manufacturer's calibration certificate must be sent to Radiation Safety.

c. Survey Instrument Battery Test

A battery check must be performed each day an instrument is used as a minimum. However, we recommend the battery test be completed each time the meter is turned on. If the battery test falls below the battery condition line, the instrument must be taken out of use until the batteries are replaced.

· Procedure for completing the battery test.

1) Move switch on base to “BAT” position.

2) The indicator needle must deflect to the “BAT TEST” range.

3) If it does not pass, you may not use the instrument! Change the batteries or call ORS for assistance.

d. Survey Instrument Operational Check

An instrument operational check must be performed with a dedicated checksource each day an instrument is used. The reading taken must fall within the range limits stated on the side of the instrument. If the reading falls outside the stated range, the instrument must be taken out of use and Radiation Safety must be contacted.

· Procedure for completing the operational check.

1) With the meter turned on, hold the probe flush against the check source location (black X) on the side of the meter. The red cap should be removed for G-M probes.

2) The display must read within the range limits on the “Checksource Measurement” sticker.

Text Box: Checksource Measurement
Date GM 0.4 – 0.6 mR/hr
12 / 31 / 05 NaI____________ cpm

3) Contact ORS if the reading falls outside the range. Do not use this instrument!

e. Effective Use of a Survey Instrument

The following information is provided to assist the RAM users in the proper procedure for performing contamination surveys with the survey instrument.

· Geiger-Mueller (G-M) Detector

1) After battery check and operational check, set the dial switch to the lowest scale.

2) “Instrument Background” is the highest reading when no radioactive material is present.

3) Average Backgrounds (end window or pancake probe)

~ 0.03 mR/hr

30 – 100 cpm

0.3 – 1 cps

If your background is too high you must move to another area, re-perform the operational check, and try again. A short in the cable or a contaminated probe can cause elevated backgrounds.

4) Always remove the red cap before surveying.

5) Proper survey distance is 1cm from the surface – don’t let the probe make contact with the object you are surveying!

6) Keep the probe face parallel to the area being surveyed.

7) You can never survey too slowly. Recommended survey speeds range from 2-5 cm/second. Keep in mind that the efficiency of your meter varies with the isotope you are trying to detect!

8) Survey with the audio “on”!

9) Reading the survey instrument

· Sodium Iodide (NaI) Scintillation Detector

Detection of gamma from I-125

1) After battery check and operational check, set the dial switch to the lowest scale.

2) “Instrument Background” is the highest reading when no radioactive material is present.

3) Average background 100 to 500 cpm

4) Results in cpm only!

5) 20-30% efficiency

6) Red cover is not removable!

7) Proper survey distance is 1cm from the surface – don’t let the probe make contact with the object you are surveying!

8) Keep the probe face parallel to the area being surveyed.

9) You can never survey too slowly. Recommended survey speeds range from 2-5 cm/second. Keep in mind that the efficiency of your meter varies with the isotope you are trying to detect!

10) Survey with the audio “on”!

f. Liquid Scintillation Counters

The liquid scintillation counter (LSC) is used to detect low energy beta-emitters (H-3). The LSC must be used for analyzing wipe samples for H-3 contamination surveys. The instrument counting results will be in counts per minute (cpm) and the average background is usually less than 50 cpm. The LSC protocols must be programmed for detection of the appropriate isotope energies.

5. Opening Packages

Packages containing radioactive material must be opened in an area designated for the use of radioactive material, such as a lab bench covered with absorbent paper. Packages containing volatile radioactive material must be opened in a functional hood.

Don gloves and carefully open the outer and inner packaging. Users should verify that the shipment contains the isotope, chemical compound, and activity ordered. Users should check the integrity of the final source container by inspecting for signs of damage, i.e., vial breakage, package discoloration, or fluid loss. Packaging material, such as the box, plastic inserts, etc. shall be monitored for contamination prior to disposal.

If any contamination is found it must be identified and the incident reported to Radiation Safety. If the packaging material is not contaminated, obliterate, cross-out, or cover with an "Empty" label all radioactive material labels prior to discarding it into the regular trash.

6. Radioactive Waste Management

This section is a brief overview of the waste management practices outlined for the research laboratories. Additional information can be obtained from the Office of Radiation Safety.

The Office of Radiation Safety manages the University's centralized waste management program. This program only allows for short term storage of radioactive waste within the research laboratories. The Office of Radiation Safety will assign the appropriate waste containers to each research group. It is the responsibility of each research group to utilize the appropriate shielding material for the storage of radioactive waste within their research lab.

Once dry solid and stock vial radioactive waste containers are full, these containers must be transferred to the Office of Radiation Safety. Radioactive material users are required to complete the manifest affixed to each waste container with the date the radioactive waste was placed in the waste container and the activity. Contact the Office of Radiation Safety at 2-6299 for pick-up when a waste container is full. Radioactive waste pick-ups are conducted on Tuesdays and Fridays. The Office of Radiation Safety will manage, track, and perform final disposal of radioactive waste removed from the research laboratories.

When contacting the ORS for a waste pick up, the following information must be provided:

· Principal Investigator’s name;

· Caller’s name and phone number;

· Isotope of waste;

· Physical form of waste;

· Waste container manifest number to be picked up; and

· Room number for pickup/delivery of containers

a. Dry Solid Waste

Radioactive waste containing radioisotopes with half-lives less than 90 days must be packaged into one of the approved waste containers issued by the Office of Radiation Safety.

Radioactive waste containing radioisotopes with half-lives greater than 90 days must be packaged into one of the approved waste containers issued by the Office of Radiation Safety. In addition, the waste must be sorted into one of the following content categories: incinerable, compactable, and noncompactible .

Please Note: Laboratory personnel must properly package and manifest the waste by recording the date waste was placed into the container and its activity. If the manifest is not properly completed the container can not be removed from the lab until the information is added to the waste manifest.

Once dry solid radioactive waste containers are full, laboratories must call the Office of Radiation Safety for pickup of the container. Replacement containers will be issued to the research laboratory upon their request.

b. Manufacturer's Stock Solution Vials

Stock solution vials regardless of half-life must be segregated from all other waste streams and placed into a container issued by Radiation Safety. Laboratories are required to properly package and manifest these vials. The Office of Radiation Safety will pick-up these vials for subsequent storage and disposal.

c. Aqueous Liquid Waste

Laboratories are prohibited from discharging liquids into laboratory sinks beyond the current applicable limits:

· One microcurie (1 µCi) per day of any radioisotope having a half-life greater than thirty (30) days.

· Ten microcuries (10 µCi) per day of any radioisotope having a half-life less than thirty (30) days.

*The applicable limits are noted on the Radioactive Aqueous Waste Drain Disposal Log.*

Laboratories are allowed to discharge aqueous liquid waste daily at the limits listed above. These limits are daily discharges per sink drain. Lab personnel conducting drain disposal must record discharges on their Radioactive Aqueous Waste Drain Disposal Log. The record must list the date, isotope, volume, activity and the initials of the individual conducting the disposal. In addition, the Office of Radiation Safety will require labs to submit their drain disposal logs each quarter.

The sink must be labeled as a sink used for Drain Disposal. These signs can be obtained from the Office of Radiation Safety.

Aqueous liquid in excess of these limits must be collected in an approved carboy and must also be properly manifested. Carboys must be transferred to the Office of Radiation Safety for disposal. Replacement containers will be issued to the research laboratory upon their request.

d. Scintillation Media

Scintillation vials containing activities of 0.05 µCi/ml or less of H-3, C-14, or I-125 may be disposed of as chemical hazardous waste. Laboratories within the medical complex are to contact the Medical Center Safety Office (2-1733) for disposal details. Laboratories outside the medical center are to contact the University Environmental Health & Safety Office (2-9999) for disposal details.

Scintillation vials containing regulated isotopes (all isotopes except 0.05 µCi/ml or less H-3, C-14 or I-125) must be disposed by the users via the Office of Radiation Safety. Contact Radiation Safety for waste disposal consultation.

Bulk scintillation cocktail (all isotopes) must be disposed by the users via the Office of Radiation Safety. Contact Radiation Safety for waste disposal consultation.

e. Biological Waste

Each researcher must be approved to perform animal experiments involving the administration of radioactive material to animals. In addition, each researcher must consult with the Office of Radiation Safety concerning the generation of animal carcass waste, feces, bedding, etc. to ensure proper disposal. The following are guidelines to follow:

1) Radioactive animal carcasses may not be stored in the Carlson Animal Resource Facility (CARF) without permission from the Office of Radiation Safety.

2) Laboratories must be able to provide sufficient freezer space for carcasses containing radioisotopes with half-lives of less than ninety days. These carcasses must remain in storage for decay to background radiation levels (minimum storage period of 10 half-lives).

3) Laboratories must label the animal waste prior to storage in the freezer. The waste must be labeled with “Caution Radioactive Material” tape, isotope, date of storage and activity.

4) Laboratories must contact the Office of Radiation Safety for monitoring of this waste prior to its release for disposal to ensure proper documentation is maintained for the release survey.

5) Contaminated animal waste, such as feces, bedding, etc. must be transferred to the Office of Radiation Safety for decay-in-storage or off-site disposal.

6) The use of isotopes of H-3, C-14 or I-125 with a specific concentration of 0.05 µCi/gram or less of animal tissue, averaged over the weight of the entire animal may be disposed of as if it were not radioactive.

7) The use of H-3, C-14 or I-125 with a specific activity of greater than 0.05 µCi/gram averaged over the weight of the entire animal MUST be disposed of as radioactive waste via the Office of Radiation Safety.

8) The waste generated from all other isotopes administered to animals MUST be disposed of as radioactive waste via the Office of Radiation Safety.

f. Organic Liquids

Please contact the Office of Radiation Safety to discuss the use of organic solvents for your radioactive experiments prior to its use.

7. Laboratory Notebooks

Laboratories are required to maintain radiation safety notebooks.

Laboratory notebooks should contain all completed Package Receipt and Disposal Forms (Radionuclide Receipt & Usage Logs), Surveys of Removable Contamination, Radioactive Aqueous Waste Drain Disposal Logs, Training Records and Radioactive Material Inventory Records. Notebooks should be readily accessible for review by Radiation Safety personnel and Regulatory Inspectors.

8. Security of Radioactive Material

There is heightened concern across the nation about acts of terrorism, therefore researchers need to be mindful of security procedures regarding the use of radioactive material.

It is the responsibility of each principal investigator to maintain sources of radiation, (including radioactive material samples and radioactive waste) under constant surveillance and control at all times. The following guidelines must be observed:

· Rooms where radioactive material is used or stored must be locked when unattended.

· Eliminate unnecessary quantities of radioactive materials.

· Maintain safe and secure storage of all radioactive material in space you are directly responsible for and space you remotely oversee.

· Be aware of unexpected visitors, make inquires and have a plan to deal with those situations.

· Report to University Police (123 or 2-8181) any individuals whose behavior you find threatening or suspicious.

· Maintain accurate contact information at laboratory entrances for use by emergency responders (contact information cards are available from the Safety Office).

It is also the responsibility of each investigator to promptly report loss, theft, or damage to any source of radioactive material (radioactive waste, stock solution vials, sealed sources, etc.) to the Office of Radiation Safety.

9. Emergency Procedures

Each lab is required to post the "Emergency Procedure" in each laboratory where authorization for use and/or storage of radioactive material has been approved. A copy of this posting can be obtained from the Office of Radiation Safety or download from the ORS web site.

Major spills, loss, theft, or damage to any source of radioactive material (radioactive waste, stock vial solutions, sealed sources, etc.) or any other accident involving radioactive material MUST be reported promptly to the individual responsible for the use of the material and to the Office of Radiation Safety.

During normal working hours (M-F, 8:30 am to 5:00 pm), call the Office of Radiation Safety at extension 2-6299 to report that a radioactive spill or radiation accident has occurred and the location. At all other times, call University Police at 2-8181 or at 123 and report that a radioactive spill or radiation accident has occurred and to please contact Radiation Safety personnel.

Persons splashed with radioactive material should wash the affected area immediately with mild soap or a decontaminating agent effective for the chemical involved. If the contamination is localized to small areas of skin, the contaminated areas should be masked off and the affected areas cleaned with cotton applicators dipped in soap or suitable decontaminating agents. Care should be taken not to scratch or erode the epidermal skin layer. All clothing suspected of being contaminated should be removed and surveyed by Radiation Safety.

[Please Note: Contaminated clothing MUST be transferred to Radiation Safety]

10. Labeling of Containers Containing Radioactive Materials

The University policy is to label each container (stock vials, samples, etc.) of radioactive material with a durable, clearly visible label bearing the radiation caution symbol and the words

"CAUTION RADIOACTIVE MATERIAL"

In addition, the container shall bear a label denoting the isotope, activity, and the reference date activity. Vials and samples containing radioactive materials placed in storage (refrigerators, freezers, etc.) must be properly labeled to ensure all staff is aware of their presence. Counting vials do not need to be labeled if they are stored in an appropriately posted area and are attended by an individual who takes the necessary precautions to prevent personnel exposure and place the vials in the appropriate waste container.

11. Radiation Safety Precautions

a. Food and Beverages

The University is committed to maintaining a safe work environment for its employees and the University Radiation Safety Committee is responsible for the control and safe use of radioactive material.

Because of the risk of ingesting small amounts of radioactive material over a long period of time, food and beverages for human consumption CANNOT be stored or consumed in radioactive material laboratories or cold rooms.

1) General Rules:

· Smoking in radioactive material laboratories is prohibited.

· The application of cosmetics (lip gloss, hand cream, etc.) is prohibited in areas where radioactive material is used or stored.

· Heating or preparing food or drinks for human consumption using microwaves and coffee makers in radioactive material laboratories is strictly prohibited.

2) Specific Rules Regarding Food/Beverages in Radioactive Material Laboratories:

Definition: Use or Storage of Radioactive Material

Any lab, cold room, or office door that has a "Caution Radioactive Material" sign posted on it is an area where radioactive material is used or stored.

In these Areas:

· Lab personnel are NOT allowed to eat food, i.e. lunches, bagels, sweet rolls, or candy, or drink any type of beverages, i.e. coffee, soda pop, water, or tea.

· Lab personnel are NOT allowed to store food or beverages anywhere in these labs, i.e. desk drawers, cold rooms, refrigerators.

Defined Areas For Eating and Drinking of Beverages

Lab personnel are allowed to eat and drink in areas that are clearly a separate space from the rest of the lab, i.e. an office within the lab with its own door. These areas need to be approved by Radiation Safety.

3) How Radiation Safety Will Inspect Laboratories

The Office of Radiation Safety will implement the following policy for food/beverage violations found in the research labs:

Principal Investigator's will be notified in writing when:

· Evidence of eating or drinking is found within the lab, i.e. food wrappers found in waste containers, beverage residue found in a coffee cup.

· Lab personnel are found eating or drinking beverages in the lab.

· Food or beverages are found on desktops, in refrigerators, in cold rooms, or in any other area within the lab where radioactive material is used or stored.

The Principal Investigator will be required to submit a corrective action plan to the Office of Radiation Safety. Periodic follow-up surveys will be conducted to ensure compliance has been met.

The Office of Radiation Safety will report food/beverage violations found in the research labs to the University Radiation Safety Committee. The committee will review each occurrence and may require additional corrective action, including fines, suspensions or termination of privileges to use radioactive material.

b. Protective Clothing

Rubber or plastic gloves and either laboratory coats or coveralls must be worn while working with radioactive material that is not in sealed source form. Gloves used while working with iodine shall be replaced frequently because iodine tends to migrate through glove material. For this reason, double gloves are recommended for iodine work. Such protective clothing must be monitored before removal and, if found to be contaminated, stored for decay in an isolated location or disposed as radioactive waste. Gloves must never be reused. In addition, shorts, skirt, and open toed shoes are prohibited.

c. Working Surfaces

Working surfaces should be covered with absorbent material that has a waterproof backing. The waterproof backing side must be down on the surface to be covered with the absorbent side up. These covers should be checked after each experiment or use. If contamination is found, discard the absorbent paper as radioactive waste and replace the absorbent material.

d. Fume Hoods

Work involving volatile liquids, gases, fine powders, boiling, dust, vapors, energetic stirring, or any other operation where radioactive materials are likely to become airborne must be performed in a hood having a minimum face velocity of 100 linear feet per minute at any point of the hood opening. The base of the hood should be covered with absorbent material that has a waterproof backing. Hood exhaust filters should be maintained in good condition in order to exhaust dust and vapors efficiently. The Plant Department should be contacted to make such measurements and to replace the filters if necessary.

Iodinations with I-125 sodium iodide must be performed in a fume hood having a minimum face velocity of 100 linear feet per minute at any point of the hood opening. When using any volatile radioactive materials, the hood should be left running at all times.

e. Mouth Pipetting

Radioactive solutions shall not be pipetted by mouth.

f. Release of Equipment Used in Radioactive Material Experiments

Prior to the release of equipment (ice buckets, centrifuges, pipetters, etc.) that were used in radioactive material experiments, the equipment must be surveyed to ensure that no residual contamination is present. All "Caution Radioactive Material" signs must be removed, to certify that no radiological hazards exist. If the equipment is to be released to a vendor for repair or released to movers for packing, the monitoring must be performed by the Office of Radiation Safety.

g. Labeling Equipment Use in Radioactive Material Experiments

All equipment (centrifuges, pipetters, pens, etc.) used in radioactive material experiments must be labeled with "Caution Radioactive Material' signs to communicate to all lab personnel the potential radiological hazard.

12. Bioassay Requirements

a. Iodine Thyroid

All users who work with a vial containing more than 1 mCi of I-125 or I-131 must have a thyroid bioassay no sooner than four hours after each iodination and no later than one week after each iodination. All users performing iodinations are required to schedule an appointment for a thyroid bioassay before any package containing more than 1 mCi of I-125 or I-131 will be released by Radiation Safety. Do not schedule a thyroid bioassay for sooner than 4 hours after performing the iodination.

A copy of the Radionuclide Package Receipt & Disposal record for each iodine package must be submitted to Radiation Safety every week, beginning with the date the material is received by the user. Either fax or deliver a copy to the Office of Radiation Safety to ensure receipt. The Package Receipt & Disposal record must list the date the material was used, amount removed from the vial, percent of activity placed into waste, and the user initials. This requirement remains in effect for the length of time the iodine stock vial(s) remains in the laboratory. Vials that will no longer be used by the laboratory must be transferred to Radiation Safety. Once the stock vial(s) is transferred, the laboratory will no longer be required to submit copies of the usage log.

Users who fail to submit a copy of the usage form within the one week time period will be notified.

Users not reporting for a scheduled thyroid bioassay appointment will be called to reschedule. If the second appointment is not kept, the worker will be called to reschedule and the principal investigator will be notified. After the third failure to report for a scheduled thyroid bioassay, the principal investigator's license will be suspended from ordering I-125 or I-131.

In repeated noncompliance situations, the University Radiation Safety Committee has authorized the Office of Radiation Safety to suspend principal investigators from ordering radioactive material.

b. Tritium

Individuals working with more than 100 mCi of H-3 in any unsealed form are required, as a condition of the University's licenses to provide Radiation Safety with a urine specimen within 4 working days of each use.

13. Exposure to Airborne Radioactive Materials

The Derived Air Concentration (DAC) may not exceed the following:

Radionuclide	DAC (µCi/ml)	Radionuclide	DAC (µCi/ml)
C-14	1 x 10-6	H-3	2 x 10-5
Ca-45	4 x 10-7	I-123	3 x 10-6
Ca-47	4 x 10-7	I-125	3 x 10-8
Co-57	3 x 10-7	I-131	2 x 10-8
Co-60	1 x 10-8	Na-22	3 x 10-7
Cr-51	8 x 10-6	P-32	2 x 10-7
Fe-59	2 x 10-7	S-35	9 x 10-7
P-33	1 x 10-6

14. Radionuclide Use Involving Animals

The principal investigator under whose application the material is obtained is responsible for posting each cage with a sign bearing the standard radiation caution sign, radionuclide, total activity in each animal, date and name of experimenter.

Animals containing radioactive material must be housed in separate cages segregated from other animals. Animal attendants should monitor themselves before leaving the area, particularly their hands and the soles of their shoes. Lab personnel are responsible for conducting area surveys after experiments as prescribed in the laboratory survey section.

Principal investigators and authorized personnel must have access to rooms housing animals injected with radioactive material. Animal housing facilities for animals containing radioactive materials must be locked at all times.

Radiation Safety, when applicable, will assign waste containers for the collection of radioactive waste (excluding carcasses).

Animal Care Facilities, cages, animal carcasses, waste, bedding/excreta, and related equipment must be held by the investigative staff until surveyed by the Office of Radiation Safety for release to the Animal Resource Staff.

Investigative staff may be issued additional protection and control instructions from the Animal Resource Committee and/or the Office of Radiation Safety. The Research Group will be required to follow these instructions.

15. Repair of Hoods and Drains

Researchers are required to notify the Office of Radiation Safety before repairs are made to laboratory drains or hood ventilation systems to determine if special monitoring is required to protect the Physical Plant worker or outside contractor.

16. Sealed Source Leak Test

Sealed sources containing either of the following licensed radioactive material must be leak tested.

Alpha emitting source (half-life greater than 30 days) having an activity of more than 10 microcuries.
Beta or gamma-emitting source (half-life greater than 30 days) having an activity of more than 100 microcuries.

Alpha-emitting sources generally require testing at three-month intervals. Beta and gamma-emitting sources require testing at six-month intervals.

It is the responsibility of the individual under whose application the source is used or stored to ensure that the leak tests are performed. Generally, Radiation Safety conducts the leak tests unless the University Radiation Safety Committee has approved an alternate means of complying with the regulations or license conditions. Access to the location of the source(s) or the device must be made accessible by the principal investigator for such testing.

G. Charges

A list of charges is available on the Office of Radiation Safety's website. The charge schedule is subject to change with a minimum of advance notice.

H. Additional Requirements

The University Radiation Safety Committee may specify additional requirements, procedures, or medical examinations, and may grant exemptions to the requirements herein specified.