Department of EnergyOffice of Worker Protection Programs and Hazards ManagementRadiological Control Technical PositionRCTP 95-06Job-Specific Radiological Worker TrainingIssue:The requirements of title 10, Code of Federal Regulations, part 835 (10 CFR 835), section 902 for radiological worker training to include training specific to, and commensurate with, an individual's job assignment have resulted in questions regarding the level of effort necessary to demonstrate compliance.Introduction:10 CFR 835, "Occupational Radiation Protection," section 902, specifies requirements for radiological worker training. Radiological worker training is provided to individuals whose job assignments involve operation of radiation producing devices or working with radioactive materials, or who are likely to be occupationally exposed to ionizing radiation at levels exceeding 0.1 rem in a year. Since January 1, 1989, this training has been provided in accordance with the requirements of the Department of Energy (DOE) Order 5480.11, "Radiation Protection for Occupational Workers." In June 1992, these requirements were augmented by provisions in the "DOE Radiological Control Manual" (RadCon Manual).10 CFR 835.902 requires that radiological worker training include procedures specific to an individual's job assignment and further requires that the level of training be commensurate with each worker's assignment. Efforts to develop documented radiation protection programs to ensure compliance with 10 CFR 835 have resulted in questions regarding the specificity of the training required by 10 CFR 835.902. Discussion:The RadCon Manual specifies three types of radiological worker training. Radiological Worker I training is provided to individuals who require unescorted access to radiological buffer areas and radiation areas. Radiological Worker II training is provided to individuals who require unescorted access to other radiological areas. Specialized radiological worker training is provided for work involving nonroutine operations or changing radiological conditions. These types of training are discussed further in G-10 CFR 835/J1, "Radiation Safety Training Implementation Guide" (IG). Both the IG and the RadCon Manual indicate that these types of training are specified to prepare individuals to work safely in the radiological environments to which they are likely to be exposed while unescorted.Both Radiological Worker I and II training include standardized core training material that is used throughout the complex. Within the standardized core training lesson plans, certain topics are flagged to indicate that development of site-specific material may be necessary to augment the core course material. Institution of the appropriate type(s) of radiological worker training as described in the RadCon Manual, augmented where appropriate with site-specific material, provides radiological workers with training that is considered specific to, and commensurate with, an individuals's job assignment. Technical Position:Based upon the information cited above and requirements of 10 CFR 835, institution of the Radiological Worker I and II and specialized radiological worker training programs as prescribed by the RadCon Manual and the IG is sufficient to satisfy the job-specific training requirements of 10 CFR 835.902. The Department recognizes that other training provided in the workplace, including mock-up training for specific jobs, trade or craft specific training, laboratory safety training, and pre-job briefings, may include specific instructions regarding radiological controls. While the Department continues to encourage comprehensive training of the work force, documentation of these types of training is not required to satisfy the requirements of 10 CFR 835.902. The extent to which documentation of additional training is required to satisfy other provisions of 10 CFR 835 should be prescribed in the documented radiation protection program developed by the operating entity and approved by the Department.References:
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