Eleven Clauses to Prevent Laboratory Contamination

Who this page is for, and what it answers

Article 12 of the instructions in decision 3 of 2007 lists eleven clauses for reducing the chance of contamination in a laboratory. Those bound to observe them are the radiation protection officers. With that duty comes a second: impressing on all the workers that they are to comply fully. The Arabic wording itself is carried verbatim in the section below, save the end of clause 5, which we have withheld; we do not reproduce the law's wording in English.

Seven terms are needed on this page. Prevention here means reducing the chance of contamination before it occurs. Work clothing is clothing kept for the laboratory alone. A radiation exposure meter is a device carried so as to record what its wearer has been exposed to. Periodic measurement is measurement repeated at intervals. The elbow is the joint of the arm. Our reading of the reach of the words: a wound below the elbow is one on the forearm or the hand, and the text sets no bound to it. Radioactive waste is material whose use has ended while activity remains in it. And the licence holder is the party holding the licence to deal with radioactive material.

The page is for whoever sees to radiation protection in a laboratory. It is for whoever writes internal rules for a laboratory. And it is for whoever trains new workers in the rules of the place.

Where this sits in the text: article 12 of the instructions attached to the decision, not of its two enacting articles. It has eleven clauses, a number counted from the text's own numbering, and the last clause has three sub-items.

The most important caution: the two duties are not the same. Observance falls on the officer, and full compliance on the workers. They are not levelled, and it is not said that the clauses address the workers in the first place.

A caution: at the end of clause 5 there is a word we regard as a probable transcription error. We have therefore withheld the end of that clause, we build no rule on it, and we do not state the possible word. The rest of the clause is rendered as it stands. That is a decision of ours which we declare, until the page image can be checked.

There is no measurement figure in this article. It names no unit of radioactive activity and no area of surface over which a rate is worked out. Numbers from one place are not imported into another.

The eleven clauses, in our rendering

The opening of the article fixes who is bound and to what end: radiation protection officers in laboratories must observe the following matters so as to reduce the chance of radioactive contamination, and must impress on all the workers that they are to comply fully. So observance falls on the protection officers, and the purpose is to reduce the chance of contamination.

The first four clauses concern clothing, place, handling and what is brought in: special laboratory clothing is used in radiological laboratories and is not taken out of them; laboratory operations and experiments are carried out in the designated areas only; the radioactive material needed is not moved or handled except under the supervision of specialists; and only the radioactive material needed for the operation or experiment is brought in, preferably one item after another.

Clause 5 concerns the tools used for absorbing or drawing up material: special and suitable tools are used for absorbing or drawing up radioactive material during experiments. Its closing words are the place we have withheld, as declared above.

Clauses 6 and 7 concern waste and gloves: radioactive waste, solid and liquid, is placed in the designated places, numbered and labelled; and tissues, gloves and the like are treated as radioactive waste, gloves being turned inside out as they are removed so that contamination does not reach the hands. Turning the glove inside out is stated, and so is its purpose.

Clauses 8 and 9 are prohibitions: persons with wounds on the hands, below the elbow, are prevented from dealing with or handling radioactive material; and food and drink are not brought into the laboratories, nor is smoking permitted, nor the bringing in of powders or cosmetic materials and tools. The first prohibits a person by description, and the second prohibits named things.

Clause 10 requires periodic measurement: radiation measurements must be taken periodically for the tools, equipment and vessels used in the laboratories, and likewise for the various areas in which any radiological practices or experiments using radioactive material take place. So what is measured is tools, equipment, vessels and the areas of practice, and the text states no interval for that periodicity.

The last clause sets three sub-items at the end of each day. Its opening provides that after work ends, and every day, the following is required: the hands, feet and clothing are checked with the radiation measuring instruments; the work clothing and the radiation exposure meters are left in the places designated for them; and the hands and face are washed well, with suitable cleaning materials and solutions where necessary.

What falls outside this article

Article 12 gives no numerical limit. It contains no measurement figure at all. The limits sit in clause 1 of article 1 and in other tables of the instructions, which have their own published pages.

It does not deal with what is done after contamination has occurred. This is an article about prevention before it occurs. What comes afterwards sits in other articles, some published and some with their own page in this batch.

It does not deal with handling waste once labelled. Clause 6 stops at placing it in the designated places, numbering it and labelling it. The reference to the instructions on managing radioactive waste sits in article 6, which has its own page in this batch.

It does not deal with the protection officer's qualification or training. We do not say what we have not read. And we do not carry a condition from another instrument into this place.

We find in the places read neither a sanction nor a period of grace. What we have not read, we do not build on.

The eleven clauses listed in the order of the text

The table below lists the eleven clauses in the order the text gives them. Take it up when you review your internal rules, 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, save the end of clause 5, as declared. The last column gives the kind of clause: an obligation, a prohibition, a limitation, a preference, or daily sub-items. The numbers in the first column are ours, while the order they mark is the text's. The table carries no measurement figure and no limit.

A case of incomplete internal rules, and four steps

Suppose a laboratory whose internal rules carry eight of the eleven clauses. The clause on gloves and tissues, the clause on periodic measurement and the clause on the end of day check have dropped out. Measured against the text, those rules are incomplete, because the clauses are eleven by its own numbering. And if all the clauses were written in while the officer's duty and the workers' duty were run together, a different flaw would remain: observance falls on him and compliance on them. That is our reading of the wording of the opening.

Step one: list the eleven clauses, numbered in the order of the text. Abridging the list drops a clause without anyone noticing.

Step two: separate the officer's duty from the workers' duty in two lines. The opening states both observance and impressing compliance, and each has its own addressee.

Step three: make the end of day check a written item carrying all three sub-items; putting it in writing is a recommendation of ours. The last clause has three sub-items and not one.

Step four: write down that the end of clause 5 is a withheld transcription point, as set out at the head of this page. The protection officer observes, impresses compliance and records: this is what we train for, not what we do for you.

Questions people ask

Notes on transcription and reading

What we work from is a written transcript, not a scanned image. Article 12 is sound in transcription throughout its clauses save in one place: the end of clause 5. We have withheld that place and have not corrected it. The remainder is rendered as it stands.

What is withheld is the transcription of one place at the end of the clause, and what precedes it is clear in its wording. We build no rule on what is withheld. The clause is one of the matters the article's opening requires to be observed. What it provides is the use of special and suitable tools for absorbing or drawing up, and the clause is clear to that extent. Its closing words are reserved until the page image from the official gazette can be checked.

A point on which the text is silent. Clause 8 bars a person with a wound below the elbow. It does not say who decides that or how it is recorded. We have not raised the question with the competent authority, so no view of theirs is reported here.

What the institute offers, its limits, and the reference

This page is about the eleven clauses for preventing contamination in a laboratory. The institute trains people to build internal rules that cover the clauses and to document the daily check.

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 12 of the attached instructions, with its eleven 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.