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April 2009

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Subject:
From:
"Stadem, Richard D." <[log in to unmask]>
Reply To:
TechNet E-Mail Forum <[log in to unmask]>, Stadem, Richard D.
Date:
Tue, 21 Apr 2009 11:02:03 -0500
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For all of you process and manufacturing engineers, this is an email
that I am sending to a distributor of X-ray and laser equipment who
requested it. I am copying Technet both to increase your awareness, or
to remind you of the requirements for registration and handling of
radiation-generating equipment.

 

Following are the general requirements of the State of Minnesota in
regards to Radiation-generating equipment, which can be X-ray machines,
XRf equipment, 

Laser soldering or laser marking machines, laser welding equipment, etc.
The requirements are slightly different for different types of
equipment, and they vary from state to state within the U.S., and vary
wildly outside of the U.S. You need to check and understand what the
local requirements are for the locality where the subject machine is
being used. There may be other requirements I have not covered here. You
need to check your own local regulations concerning this.

 

1.       Controlled Access.

The machine must have controlled access. This can be either a
key-operated switch that enables the machine to be turned on and off,
with control over the location of the key (typically controlled by a
Master Key person) or a secure software password that disables itself if
the machine is sitting idle. If a key is used, it cannot be left in the
keyswitch when the key operator is finished using the machine.

The objective is to prevent any untrained and uncertified personnel or
outsider from being able to activate the radiation-generating portion of
the machine.

2.       List of Certified Operators Posted.

A list of certified operators shall be posted on the machine. These are
operators who may or may not have controlled access, but anyone
operating the machine must have passed a Hazardous Radiation Handling
class including a written test that is approved by the State of
Minnesota (you can get this from OSHA), and must be recertified each
year. In addition, there must be a secondary class that they must attend
that teaches "in comprehensive detail" how to operate the machine,
including the location of all safety features and knowledge of use.

3.       Radiation Hazard Warning Labels

These must be posted on the front of the machine, or the side of the
machine where access to the chamber is made. In addition, black and
white striped Hazardous Radiation tape should be on the floor in front
of the access door. For pass-through conveyorized machines, both ends
must have the tape on the floor.

4.       Radiation Leakage Test Performed (for X-ray or XrF equipment)

A radiation leakage test must be performed around the entire outside
surface of the machine. This can be done by purchasing or leasing a
NIST-calibrated Geiger counter, or as part of the maintenance agreement
with the machine vendor. However, the dated leakage test results must be
posted on the machine where it is easily visible, and must include the
method used, the measured radiation, and who performed the inspection.

5.       Machine Operation Instructions Posted

Comprehensive instructions for operation of the machine shall be posted
on the machine. This can be either the operating manuals from the
machine vendor or documented instructions written and maintained by the
user.

6.       Registration of the Radiation Generator

In Minnesota, the X-ray tube, laser generator, or other radiation source
must be registered with the State, and a copy of the registration should
be posted on the machine. When an X-ray machine is deactivated, you want
to contact the State or your local regulator to ensure the registration
is noted as deactivated, and you want to make a note with the State if
the machine is sold or scrapped.

 

I know of more than one process engineer who has spent the better part
of a week attempting to trace the equipment, hunting through used
equipment warehouses, junkyards, and competitor's facilities attempting
to track down the current location of a piece of radiation equipment.
The state is required to perform audits on this procedure, and I pity
the poor sucker who forgets to de-list the equipment.

 

You want to make sure all of the requirements are in place. If the OSHA
people come into your facility, the first thing they look for is
radiation equipment. If they find the machine is being operated without
the above controls, the result is usually an immediate plant shutdown
until all corrective action is finished, followed by expensive fines.  I
don't want this to happen to anyone, hence this message. It is often
overlooked or forgotten.


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