Contaminated Tools and When They Are Treated as Waste

Who this page is for, and what it answers

A contaminated tool in a laboratory is treated as radioactive waste if the level of its contamination has not fallen to the permitted limits. That is stated in clause 5 of article 6 of the instructions in decision 3 of 2007. A second rule comes with it: the cleaning solutions produced by the removal are radioactive waste too. The Arabic wording itself is carried verbatim in the section below; we do not reproduce the law's wording in English.

Six terms are needed on this page. Tools and vessels are the laboratory's glassware, containers and the items used in it. The half life is the period in which the activity of a material falls to half. Radioactive decay is a spontaneous change in the material's nuclei by which its activity declines over time. Radioactive waste is material whose use has ended while activity remains in it. Wiping in clause 4 is coupled with washing. Our reading: what is meant is cleaning the tool, not a radiation measurement and not the taking of a laboratory smear; the text does not explain the word. And the licence holder is the party holding the licence to deal with radioactive material.

The page is for the radiation protection officer in a laboratory. It is for whoever decides whether to clean a tool or replace it. And it is for whoever separates radioactive waste from other waste in the laboratory.

Where this sits in the text: article 6 of the instructions attached to the decision, not of its two enacting articles. It has eight clauses, a number counted from the text's own numbering.

The most important caution: the clauses are not all in the same form. Some are cast as an obligation, some as a permission, one as advice, and some in none of these forms. We do not level the forms, and we do not turn a permission into an obligation.

The trigger that turns a tool into waste is a stated form of words and not an estimate of ours: that the level of contamination has not fallen to the permitted limits. Those limits sit in clause 1 of article 1 and in other tables, which have their own published pages.

This article carries no measurement figure at all. It names no unit of radioactive activity and no area of calculation in its clauses. Numbers from one place are not imported into another.

What article 6 provides, clause by clause, in our words

Clause 1 fixes where the washing is done and under whose supervision: the laboratory's bottles and vessels are washed in a designated place and under the supervision of specialists. So two qualifiers are stated: a designated place, and the supervision of specialists.

Clause 2 provides for a comparison of costs: the cost of decontamination is compared with the cost of new tools, and the economically sounder option taken. The clause carries neither an obligation nor a permission in form, so we make it neither. The test it names is the better economic case.

Clause 3 deals with short lived contaminants: materials and tools contaminated with short half life contaminants are placed in plastic bags, closed tightly, marked with suitable warning signs, and left for a period sufficient for their radioactive activity to cease through decay. So four acts are stated: plastic bags, tight closure, marking with signs, and leaving them for a sufficient period.

Clause 4 requires the removal tools themselves to be wiped and washed so that they do not spread the contamination: the tools, equipment and devices used for decontamination must themselves be wiped and washed, so that contamination is not spread to other areas, vessels or tools when they are used again. So the clause is cast in the form of an obligation, and not a permission.

Clause 5 is the waste trigger: materials, tools and vessels whose level of contamination has not fallen to the permitted limits are to be treated as radioactive waste, the cleaning solutions produced by the removal are themselves radioactive waste, and the instructions on managing radioactive waste apply to them. So there are two rules here, and the instructions on managing radioactive waste are a separate instrument that we name as a reference and do not quote.

Clause 6 is a permission and not an obligation: the danger of the contaminating material may be reduced by using stable chemicals similar to the radioactive one, with attention to any other hazards that material may carry. So the use of similar stable chemicals is cast as a permission, and it carries an express caution about that material's own hazards. Our reading: the reduction the clause speaks of concerns the material's behaviour and not its radioactive activity, which adding a stable material does not reduce.

Clause 7 is likewise a permission: brushes may be used to remove contamination from glass tools and vessels, lightly. So brushes are named for glass, in the form of a permission. Our reading: the qualifier attaches to the removal, and the text sets no degree of contamination. And on the same reading: the brush itself picks up contamination and so falls under the wiping and washing that clause 4 requires, and dry brushing raises contaminated dust.

Clause 8 advises keeping certain materials in the laboratory: the materials listed are said to be among the most used decontaminating agents, and keeping them in every laboratory that handles radioactive material is advised. So the form is advice and not obligation. The names of the materials appear in the first subsection below.

What falls outside this article

Article 6 gives no numerical limit. Its waste trigger is a form of words and not a figure. The permitted limits sit in clause 1 of article 1 and in other tables of the instructions, which have their own published pages.

It does not set out how radioactive waste is handled once marked. That belongs to the instructions on managing radioactive waste, which are a separate instrument. We name them as a reference, and we neither quote them nor describe their content.

It does not deal with contamination of surfaces and benches, or of clothing. Each of those has its own article, and they share a page in this same batch.

It does not deal with the verification survey, that is the radiation measurement, or with notifying an incident. Both of those sit in other articles of the instructions, which have their own published pages.

We have read nothing in article 6 about a sanction or a period. We pass no judgement on what has not reached us in words.

The eight clauses of article 6 and the form of each

The table below gathers the eight clauses of the article and the form of each. Take it up when you write your procedure, not on a first reading.

The middle column summarises each clause in our words, and the fuller rendering of it sits in the transcription section above. The last column gives the form of the clause as the text gives it: an obligation, a permission, advice, or none of these. The numbers in the first column are ours, and the order is the text's.

A case of a contaminated glass flask, and four steps

Suppose a glass flask used in an experiment with a short lived material. Contamination remains on it after washing in a designated place. Clause 3 provides for placing it in plastic bags, marking it and leaving it to decay, in neither obligation nor permission form. Clause 2 sets the cost of removal against the price of a new flask. If the contamination has not fallen to the permitted limits, clause 5 has it treated as radioactive waste. The cleaning solution produced by the removal is itself radioactive waste, expressly under clause 5.

Step one: require in your procedure the designated place and the supervision of specialists for the washing. These are the two qualifiers of clause 1. The clause states no exception for a small tool, and that is our reading.

Step two: set the cost of removal against the price of a new tool in your procedure. The test the clause names is the better economic case. Writing that comparison out is a recommendation of ours for review, not a provision of the clause.

Step three: require in your procedure that the cleaning solutions be kept apart from other waste; keeping them apart is a recommendation of ours. Clause 5 expressly makes them radioactive waste and refers their handling to the instructions on managing radioactive waste.

Step four: record the reading before and after removal with its date. The test in clause 5 is whether the level of contamination has fallen to the permitted limits, and what is written down can be reviewed. The protection officer removes, records and classifies: this is what we train for, not what we do for you.

Questions people ask

Notes on transcription and reading

Article 6 is sound in transcription: it contains no symbol and no figure whose reading is in doubt. Nothing on this page is withheld. Another article of these instructions has a place we withheld, and it is declared on its own page.

The names of the six materials are carried as a list, in the order the clause gives them. We have added to them no chemical formula, no concentration and no method of preparation. That is a decision of ours which we declare, and not a gap in the text.

A point on which the text is silent: clause 5 makes the waste trigger a failure to fall to the permitted limits. It does not say after how many attempts at removal that is said to be so. We have not put the question to the competent authority, and no view of theirs is given here.

What the institute offers, its limits, and the reference

This page is about contaminated tools and vessels and when they are treated as radioactive waste. The institute trains people to read the trigger in clause 5 and to document the reading before and after removal.

ALDuha Institute for Training and Environmental Consulting works in training and consulting. Its training is licensed. It does not run a laboratory analysis service for smears. It does not calibrate radiation survey instruments. It does not test equipment or certify it as safe. It does not carry out decontamination in a laboratory or on a site.

The institute does not provide first aid, treatment or medical assessment. We train people to read the text and to write down what happened.

Decontamination is the work of the licence holder and his radiation protection officer. Where outside expertise is needed, it is arranged through specialist partners. We train people to read, measure and document. We do not do the work in place of the licence holder.

Neither our training nor our consulting gives any undertaking that a licence will be issued. There is no undertaking about how long an approval will take. That decision belongs to the competent authority alone.

Reference: decision 3 of 2007 of the chairman of the Supreme Council for the Environment and Natural Reserves, on radioactive decontamination instructions. Location: article 6 of the attached instructions, with its eight clauses. The decision rests on decree law 31 of 2002, and on the executive regulation issued by decision 4 of 2003. The decision's own preamble points in particular to article 17 of the first and article 97 of the second. We name the two enabling instruments and carry the preamble's reference to them, and we do not quote their text.

A note on the names of authorities: the decision was issued by the Supreme Council for the Environment and Natural Reserves. The authority addressed today is the Ministry of Environment and Climate Change, which houses the Radiation Protection Department. The name has changed; the duty remains.

This page is an introductory explanation of a published text, and is not a legal opinion. It does not replace reading the decision itself. It does not replace checking with the competent authority.