THROUGHOUT THE United States, state radiation control programs are responsible for many aspects of radiation protection under their purview. Although some federal agencies have a specific role in radiation protection at the federal level, radiation control programs have been established in each state, New York City, the District of Columbia, Los Angeles County, and Puerto Rico. Most of these state, local, and territorial programs, under legislative authority and mandates, address all aspects of radiation protection from sources of radiation not exclusively under federal control. This includes the use of some sources of radiation not regulated by the federal government, including industrial and medical uses of x ray (other than mammography) as well as certain types of naturally occurring radioactive material.
The role of state health physicists is ever-evolving, and the scope of their work is constantly expanding. In addition to regulatory duties involved with the control of radioactive material and radiation machines (x ray and accelerators), as well as sources of nonionizing radiation such as lasers and ultraviolet radiation in some states, state radiation control staff are also involved in environmental radiation issues and preparing for radiation emergencies. Additional technical responsibilities in the areas of source security and preparation for radiological emergencies differing from nuclear power plant preparedness require additional training and knowledge.
In addition to expanded responsibilities that require more training for state health physicists, there is an increasing need to fill the gaps left by retirements and staff leaving state government for greater salary and benefits elsewhere (NCRP 2013).
CHANGES IN SCOPE OF STATE HEALTH PHYSICISTS’ ROLES
From 1963 to the present, 37 states have entered agreements with the U.S. Nuclear Regulatory Commission (NRC). In those states, termed “Agreement States,” radiation control program staff are responsible for regulating all non-federal and non-reactor facilities that possess radioactive material covered under the U.S. Atomic Energy Act (AEA), as amended (AEA 1959). These state programs currently regulate 86% of the non-reactor licensees in the United States and all of the current commercial low-level radioactive waste facilities. In addition, two other states are in the process of seeking Agreement State status with NRC, which will increase the percentage of licensees regulated by state programs.
All state and territorial regulatory programs are responsible for regulating the use of radiation-producing machines, including those used in medicine, dentistry, and veterinary medicine for diagnosis and treatment; industry; academia; and research. The number of these devices in use and the complexity of many of the newer diagnostic and therapeutic modalities have increased over time.
States also have the responsibility for non-AEA radioactive material, including technologically enhanced naturally occurring radioactive material (TENORM). This area of regulation has gained much more attention in the recent past due to an increase in nonconventional drilling for oil and gas in the states. This process, which includes hydraulic fracturing (or “fracking”), has associated TENORM issues, which now occur in some states that had not previously had to deal with TENORM on a wide scale, thus stretching the workforce needs further.
In addition to regulating radiation machines and some types of radioactive material, states also have the responsibility for regulating the uses of nonionizing radiation, such as tanning facilities or facilities that use lasers or microwave devices. Most states also provide outreach and information on indoor radon reduction, and some states implement laws regarding radon, including building codes for radon-resistant new construction and regulation of radon testers and mitigators. For states that have radiochemistry laboratories, state health physicists coordinate with the chemists and may help train them in radiation analytical techniques. Additional state laws and the increased regulatory scope of radiation control programs usually require the addition of trained health physics staff.
Those states in the planning zones of nuclear power plants are involved in off-site emergency planning and exercising, including scenario development, accident assessment, contamination control, and environmental monitoring. Currently there are 32 states in such planning zones. State health physicists also conduct incident investigations such as those involving lost or stolen radioactive sources, smelting of radioactive sources at scrap facilities, and transportation incidents involving radioactive material. Each scenario creates its own set of unique health physics and procedural tasks and coordination with other agencies and entities.
Since the events of 11 September 2001, radiation control programs also are involved in planning for other radiological incidents, including terrorist acts. States and local governments that have experience in emergency planning have been shown to be better equipped and prepared for handling other types of radiological incidents; however, preparing for radiological dispersal device (RDD) and improvised nuclear device (IND) events presents unique challenges to all programs and their staff. The application of computer techniques for accident assessment is different for RDD and IND events than in assessment of nuclear power plant emergency situations. Thus, additional training is required for state staff in both states that have nuclear power plants and those that do not in order to address planning for IND and RDD emergencies.
In addition to the changes in the scope of emergency planning and response responsibilities over the last few years, changes in other aspects of state health physicists’ roles in radiation protection have occurred. In radioactive material regulation, additional source security requirements have been implemented for radiation sources, including U.S. implementation of the International Atomic Energy Agency’s Code of Conduct for Category 1 and 2 sources, a source tracking system for radioactive sources, and codification of source security requirements into federal and state regulations. Source security issues also have led to studies on the feasibility of conversion of uses of some of the high risk radiation sources to alternate, non-source technologies, such as x ray and accelerators for blood irradiation, radiation therapy, and research irradiation techniques. These new regulations require more staff time and training.
Complex decommissioning issues involve greater use of computer modeling for assuring that licensees have complied with release criteria for license termination. Also, smelting of some radioactive sources at scrap facilities not previously licensed for radioactive material has created some challenges in decontamination assessments as well. In addition to the technical issues that have increased in decommissioning, state health physicists now are involved in making financial security determinations for facilities with large amounts of loose radioactive material, an area in which few scientists, including health physicists, are well versed. States are also considering expanding the requirements for financial security to include disposal costs for sealed sources of radioactive material.
Emerging technologies, especially in medical, dental, and veterinary medicine applications, present ever-changing training needs for radiation control staff. In recent years, large proton therapy centers have been built in a number of states. Also other complex modalities, including those using mixed radioactive material and x ray, such as positron emission tomography-computed tomography and single-photon emission-computed tomography for diagnosis and mixed radioactive material and magnetic resonance imaging for therapy, require knowledge in all areas of radiation protection or different inspectors and permitting staff. Training on radiation protection for new and blended technologies is expensive for state personnel but must be maintained in order to keep up with the complexities of the radiation protection issues involved.
Like many other employers of health physicists, state radiation control programs face a loss of personnel over the next few years as “Baby Boomers” retire (NCRP 2015). In addition, due to state salaries being characteristically lower than those of federal agencies and institutions that employ health physicists, state agencies have difficulty in retaining trained staff (NCRP 2013). To address the retirement and retention issues and to attract new qualified health physicists, states have a greater need for competitive salaries and benefits. Some states have been able to recruit and retain radiation protection professionals with the prospect of good healthcare benefits and a defined retirement income at the end of their careers. However, most state agencies must “grow their own” qualified staff through hiring individuals with a basic science or radiologic technology degree and providing additional training provided by NRC, the Oak Ridge Institute for Science and Training, the U.S. Food and Drug Administration, the Federal Emergency Management Agency, and the Conference of Radiation Control Program Directors (CRCPD). This training takes months to years for staff to obtain all the skill sets needed in their roles as a state health physicist (NCRP 2013).
Another workforce need that is unique to agencies that are required to respond to radiation emergencies is surge capacity at the state and local level in the event of a major radiation incident. This is currently being addressed through mutual aid agreements among states. Other methods are being explored and tested, such as the use of radiation volunteers through the Medical Reserve Corps and the Radiological Operations Support Specialist program.
ROLE OF CRCPD IN ADDRESSING TRAINING AND KNOWLEDGE TRANSFER
To develop a consistent and scientifically sound approach to radiation protection policies across state and federal agencies and to avoid unnecessary duplication of effort, the CRCPD fosters the exchange of ideas and information among the states and the federal government concerning radiation control. It also provides a forum for state and federal agencies to work together and apply their limited resources to address radiological health issues of mutual interest.
CRCPD uses working groups assigned to specific issues to provide guidance on new technologies and challenges. Their white papers, online training modules, electronic inspection procedures and forms, regulatory guidance, and model regulation assist state radiation control programs and save staff time.
CRCPD’s annual meetings include presentations and special interest discussions of issues of mutual interest, new developments in the field, upcoming challenges, and recommendations. These keep state and federal regulatory personnel informed and educated on technologies, issues, and regulatory procedures. Several partnering organizations, including the American Association of Physicists in Medicine, the American College of Radiology, and the American Society for Radiation Oncology, provide experts as presenters at healing arts-related workshops and training courses held in conjunction with its annual meeting.
The roles of state health physicists have evolved rapidly, especially in the past few years. New issues involving TENORM, new radiation machine technologies, source security, and emergency response call for increased knowledge transfer and consistent regulatory guidance. There is an increasing need to fill the gaps left by retirements and staff leaving state government for greater salary and benefits elsewhere. As a result of all these factors, basic training and additional specialized training are in constant demand for state health physicists (NCRP 2013).
CRCPD, its federal partners, and associated societies provide forums for these issues to be addressed and to conduct training on emerging issues and technologies. As a result, state health physicists are better prepared to address the new issues and challenges as they arise. However, even these efforts are not keeping pace with the training requirements for state health physicists, and more of this type of training will be needed in the future.
Atomic Energy Act of 1954, as amended. 68 Stat. 921; 42 USC 2011 et seq. Public Law 83‐703; 1954; Public Law 86‐373, 1959.
National Council on Radiation Protection and Measurements
. National crisis: where are the radiation professionals? (WARP). Bethesda, MD: NCRP; 2013. Available at http://ncrponline.org/wp-content/themes/ncrp/PDFs/WARP_Workshop_Summary.pdf
. Accessed 28 April 2016.
National Council on Radiation Protection and Measurements
. Where are the radiation professionals (WARP)? Bethesda, MD: NCRP; Statement No. 12; 2015.