Eight Immediate Steps After Laboratory Contamination

Who this page is for, and what it answers

When radioactive contamination occurs in a laboratory, article 4 of the instructions in decision 3 of 2007 requires eight immediate steps before the contamination is removed. The first of them is notifying two authorities. The actor named is the radiation protection officer, in coordination with those concerned with radiological emergencies in the laboratory.

Four words are needed on this page. An incident here is the occurrence of radioactive contamination in a laboratory. An immediate step is one taken without delay. Those concerned with radiological emergencies are the people named in the laboratory for that purpose. And evacuation is the removal of people from the work area.

The page is for the radiation protection officer. It is for whoever writes the radiological emergency plan in a facility. And it is for whoever reviews a written plan and wants to know whether all eight are covered.

Where this sits in the text: article 4 of the instructions attached to the decision, not of its two enacting articles. Its opening fixes the actor, the timing and the order.

The most important caution: these are steps that precede removal, not steps of removal. The wording of the opening is before the contamination is removed. So whoever starts cleaning before them has reversed the order the text sets.

Three qualifiers in the opening of the article are stated in terms. The actor is the protection officer. The coordination is with those concerned with radiological emergencies in the laboratory. And the timing is immediately and before removal. All three are conditions for reading the eight steps.

Two of the eight involve action on the body. We render the regulatory duty in them with the qualifier the text attaches, and we do not turn it into a step for an injured person to carry out. First aid and treatment belong to the medical bodies the text names.

The eight steps as the instructions of 3/2007 state them

The opening of the article provides that where radioactive contamination occurs in a laboratory, the radiation protection officer, in coordination with those concerned with radiological emergencies in the laboratory and before the contamination is removed, must take the following steps immediately. So the occasion is contamination in a laboratory, the act is taking the steps, and the timing is immediate.

Notification comes first: the step requires notifying the Supreme Council for the Environment and Natural Reserves and the Civil Defence Department as soon as the incident occurs. So two authorities are named, and the timing is as soon as the incident occurs.

Then the work area is evacuated: the step requires evacuating the work area of people except those suspected of being contaminated, until they are examined and found free of contamination. So the evacuation is general, with an exception for those suspected of contamination, who stay until they are examined. We read their staying as being under examination and not as a sanction on them; that is our reading, and the text gives no reason.

Then approach is prevented: the step requires preventing approach to the contaminated area except by the people concerned with removing the contamination and with radiological emergencies, by placing barriers that carry radiation warning signs. The means is stated: barriers carrying radiation warning signs. Those excepted are the people concerned with removal and with emergencies.

Then contaminated clothing is removed: the step requires removing the contaminated clothing and beginning the washing of the contaminated parts of the body under the supervision of specialists. The stated qualifier is under the supervision of specialists. It is a regulatory duty bound by supervision, and it is not read as an instruction for anyone to act on alone.

Then treatment, if needed: the step requires carrying out the treatment measures, if needed, by summoning the physicians who specialise in treating radiation injuries. The condition is if needed, and the means is summoning those physicians. The text names no means in this step other than summoning them.

Then the boundaries of the contaminated area are continuously verified: the step requires continuously verifying and updating the boundaries of the contaminated area by taking radiation measurements in any new areas into which the contamination may have spread. So the boundary is not fixed, and measurement is repeated in any new areas.

Then the uninjured people are examined: the step requires examining the uninjured people who were present in the area when the incident occurred, to confirm that they are free of radioactive contamination. Then those who left the area are followed up: the step requires following up any people who left the area when the incident occurred. The last of them reaches whoever went out before being examined.

What falls outside this article

Article 4 does not deal with removing the contamination itself. The wording of its opening is before the contamination is removed. Those sit in other articles, belonging to a later batch in this series. We name them and do not describe their content here.

It gives no numerical limit, and no area of surface over which a rate is worked out. The limits sit in other articles of the instructions, which have their own pages. Numbers from one place are not imported into another.

It does not deal with the detail of internal and external personal contamination. That is another article, with its own page in this batch. This is an article about an incident in a place.

The article does not deal with handling the waste produced. The instructions on managing radioactive waste are a separate instrument; we name them as a reference and do not quote them here.

The places we have read in these instructions contain no penalty and no transition period. So it is not said that failing to notify carries a particular sanction. What we have not read, we do not judge.

The eight steps listed in the order of the text

The table below lists the eight steps in the order the text gives them. Read it when you build your plan, and skip it on a first reading.

The last column names the actor or the authority as the text gives it. Where the text names no one, we attribute the reading to ourselves. The middle column summarises what the text provides, in our words. The numbers in the first column are ours, and the order they mark is the text's. The table carries no figure and no limit, because the article contains no measurement figure.

A case of a spill in a laboratory, and four steps

Suppose a radioactive solution spills on a bench in a laboratory, with three workers in the room. One of them steps into the corridor before anyone knows of the spill. All eight steps are required, and the eighth reaches that very person. Notification comes first, not after cleaning. Had the officer begun by wiping the bench, he would have reversed the order set in the opening of the article. Had he examined only the person suspected of contamination and left the worker who stayed in the room, the seventh step would have been dropped. That is our reading of the order, and not a provision about any particular period.

Step one: write the eight into your plan, numbered in the order the text gives them. A plan that names six is incomplete, and shortening it drops a step without anyone noticing.

Step two: put notification at the head of the plan, with the names of the two authorities. The text names them, and today the addressee is the Ministry of Environment and Climate Change.

Step three: state the supervision qualifier where the text states it. What touches the body is bound by the stated qualifier that it be under the supervision of specialists, and treatment is by summoning the physicians who specialise in treating radiation injuries. No step is written for an injured person to carry out alone.

Step four: record the time of each step and who took it. A report without times cannot be reviewed. The protection officer notifies, evacuates, measures and writes it up: this is what we train on, not what we do for you.

Questions people ask

Notes on transcription and reading

Article 4 is sound in transcription, containing no symbol and no figure whose reading is in doubt. So we have withheld nothing from this page. What we have withheld elsewhere sits in other articles of the instructions and is declared on their own pages.

Two of the eight involve action on the body, and each is rendered with the qualifier the text attaches. The fourth is bound by the stated qualifier that it be under the supervision of specialists, and the fifth by summoning the physicians who specialise in treating radiation injuries. We neither explain nor detail any step on the body, since that lies outside our role.

A point the text leaves open: the seventh step requires the uninjured to be examined and does not name who examines them. Whether the protection officer examines them with a survey instrument or a medical body does, it does not say. We have not raised it with the competent authority, and we attribute no statement to them.

What the institute offers, its limits, and the reference

This page is about the eight immediate steps when contamination occurs in a laboratory. The institute trains people to build a plan that covers all eight and to document what happened.

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. First aid and treatment belong to the medical bodies the instructions name. We train people to know who is notified and when, and to write down what happened.

Surveying and decontamination are 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, issued on the recommendation of the radiation protection committee. Location: article 4 of the attached instructions. 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 changed and the duty stands.

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.