Operational Topic This article describes the program prospectus, displaying various program indicator parameters and trends in a format similar to that used in a commercial enterprise prospectus provided to potential investors for a succinct and easily digestible snapshot of program activities and trends.

An Updated Radiation Protection Program Prospectus Based on 20 Years of Data Describing Program Drivers and Activities Robert J. Emery and Janet M. Gutierrez*

Abstract: In 1992, the University of Texas Health Science Center at Houston (UTHSCH) Radiation Safety Program began assembling data on a monthly basis that described various program drivers and associated activities. At the end of calendar year 2002, a decade of data had been collected, so the information was summarized into a novel program prospectus, displaying various program indicator parameters in a format similar to that used in a commercial enterprise prospectus provided to potential investors. The consistent formatting of the data afforded a succinct and easily digestible snapshot of program activities and trends. Feedback from various program stakeholders, even those unfamiliar with radiation safety matters, was overwhelmingly positive. By the end of 2012, a total of 20 years of data had been collected, so an updated and slightly modified prospectus was created. The summary document has helped to describe the drivers of the program, revealed some interesting trends, and has aided in maintaining program support even

*The University of Texas Health Science Center at Houston, Environmental Health & Safety, 1851 Crosspoint Drive, OCB 1.330, Houston, TX 77054. The authors declare no conflict of interest.

in challenging economic times. The data summary has also proved to be useful in making future projections regarding program needs. Health Phys. 107(Supplement 2):S153–S157; 2014 Key words: operational topics; operational safety; radiation protection; safety standards

INTRODUCTION Health and safety programs are traditionally evaluated by various stakeholder groups by the number of reported injuries and illnesses for a particular place of work (Brauer 1990). Because radiation safety programs rarely encounter such recognizable health outcomes, other means of program assessment are used. The results of compliance inspections are sometimes used as a surrogate measure of program performance, but this measure can be affected by inspector bias and other confounders, so reliance on this indicator can

Janet McCrary Gutiérrez is Safety Manager of the Radiation Safety Program within the Environmental Health & Safety department of The University of Texas Health Science Center at Houston. She supports the broad scope permit for the research and medical use of radioactive materials, medical and research uses of x rays and lasers. She has over 15 y of experience in radiation safety. She earned her doctorate of public health in occupational health and her master of science in industrial hygiene from The University of Texas at Houston School of Public Health. She earned her B.S. in radiological health engineering from Texas A&M University. She is a certified health physicist. Her e-mail is [email protected] Operational Radiation Safety

sometimes be misleading (Emery et al. 1997, 1998, 2000). The absence of a generally accepted barometer of ultimate radiation safety program performance makes garnering or maintaining program support a constant challenge for many radiation safety professionals. Recognizing the difficulty in communicating the relative status of its operations in succinct terms, The University of Texas Health Science Center at Houston (UTHSCH) Radiation Safety Program initiated a process in 1992 to assemble data on a monthly basis that described key operational parameters. The data is used to routinely report to various program stakeholders the scope of activities undertaken by the unit. The close of calendar year 2002 marked 10 y of intensive data collection, so, in recognition of the anniversary, a summary prospectus was created to succinctly communicate the activities carried out over the previous decade (Emery and McCrary 2003b). The term “prospectus” was used to describe the data summary because of the connotation carried by its definition: “a preliminary printed statement that describes an enterprise

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and that is distributed to prospective buyers, investors, or participants” or “something that forecasts the course or nature of something” (Webster 1990). The connotation of this term proved to be quite useful in establishing the desired tone to be associated with the document.

PROGRAM DESCRIPTION AND METHODS The UTHSCH Radiation Safety Program oversees three primary radiation use permits: one broad scope license for radioactive materials, and two registrations for radiation producing devices, one for x-ray producing devices and one for lasers. The Radiation Safety Program also oversees the possession of cyclotron activated components after the storm damage to the cyclotron from Tropical Storm Allison in 2001. In addition to a designated radiation safety officer, the program hosts an operations manager and four technical staff. One or two student interns also regularly work with the program. The daily activities of the staff include the performance of routine workplace surveys, delivery of packages of radioactive materials and issuance of personnel dosimetry devices, all described previously (Emery et al. 1995, 1996; Emery and Charlton 1999; Emery and Savely 1997). The activities of the program are routinely reported to the institutional Radiation Safety Committee, which consists of faculty, administrative, and student representatives of the various schools and departments involved with research or clinical activities. Periodic summary reports are also provided to executive leadership. As the radiation safety program conducts its daily operations, each staff member records data describing their respective activities. At the end of each month, the activity data is coalesced and entered into a single activity report, which is then provided as a standing agenda item on the monthly Radiation Safety Committee agenda (Emery S154

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and McCrary 2003b). The data is also used in a variety of reports created to describe departmental and divisional activities. Although the data is provided to the committee on a monthly basis, the only context typically afforded to the committee members is the data from the previous month or the year-todate. In other words, the data was not routinely compared to the work of previous years. It was this observation by the committee that served as the catalysis for the creation of the original 10‐y prospectus.

The data accumulated over the 10‐y time frame from 1992 to 2002 was assembled and summarized into yearly increments (Emery and McCrary 2003b). Summary graphs were then created based on the identification of key program drivers and performance indicators. Parameter selections were based on the consistent availability of the data over the 10‐y period and the parameter’s perceived value in providing an indication of overall performance. The indicator parameters selected for inclusion

FIG. 1. Twenty-year prospectus of UTHSCH radiation safety program operations, 1992 to 2012. www.health-physics.com

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in the 10‐y prospectus included the number of authorized users, number of laboratories approved for radioactive material use, numbers of dosimetry devices issued, number of radiation safety surveys performed, number of radiation safety related deficiencies noted during surveys, number of reported radiation safety incidents, and radioactive waste disposal cost expenditures. Each of these parameters was shown in context with the institution’s extramural research expenditures, a generally recognized indicator of research activity within a university (National Science Foundation 2013). For the 20‐y prospectus, the graphs depicting data on the routine surveillance program (namely, the number of radiation safety surveys performed, number of radiation safety related deficiencies noted during surveys, and number of reported radiation safety incidents) were removed and replaced with summaries of the annual amount of radioactive materials received, the number of x-ray machines, and the number of Class 3 B and 4 lasers. A companion graph, shown in Fig. 2, was also created that summarized the numbers of regulatory agency compliance inspections that occurred over the 20‐y period, separated by those with no findings of non-compliance and those with one or more findings of non-compliance.

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is interesting considering the overall growth in research expenditures. This is evidence of the shift in the technologies being used in modern biomedical research. A drastic decrease in the number of dosimetry devices starting in 1996 is displayed (Fig. 1). This drastic decrease is in direct contrast to the growth of the university research enterprise. This decrease was due to changes in the regulatory requirements for the issuance of dosimetry that were enacted by the U.S. Nuclear Regulatory Commission in 1992, and subsequently embodied by agreement state regulations in 1994 (U.S. NRC 1992). An increase in dosimetry devices is noted, starting in 2009, which was due primarily to two reasons. First, a new initiative began to improve tracking of occupational doses for healthcare providers who receive exposures at several different facilities. Second, the opening of a new School of Dentistry building that contains a large number of dental x-ray machines in a configuration different than the previous building’s floor layout. One of the more compelling graphs displays the costs associated with radioactive waste disposal. The tangible results of a

very aggressive radioactive waste minimization and management program are readily evident. Again, this decline is made even more compelling when viewed within the context of the growth of the research enterprise. The total activity of unsealed radioactive material received has declined in recent years again showing the shift in technologies being used in modern biomedical research. The peak in 1998 was from the receipt of 62Zn (62Cu) generator systems during this time period. The total activity of unsealed radioactive materials received at the institution is one way to get a high level overview of overall use of radioactive material at the institution. Two other graphs showing increases in the numbers of x-ray machines and Class 3B and 4 lasers indicate a significant shift in the types of sources the program manages. Whereas the use of radioactive materials has declined, the use of radiation producing devices has increased in both the clinical and research settings. The increase is also seen in the veterinary research applications with both x rays and lasers. A similar upward trend has been seen in overall

RESULTS The 20 y summary prospectus is displayed in Fig. 1. A steady growth in the institution’s research enterprise is evident over the 20‐y period, with a slight decline noted in year 2012. This decline was not unique to UTHSCH, as it reflects the reduction or elimination of certain federal grants that were made available as part of the American Recovery and Reinvestment Act of 2009 (ARRA 2009). The graphs reflecting the numbers of authorized users and authorized laboratories indicate a downward trend over the 20‐y period, which Operational Radiation Safety

FIG. 2. Number of radiation regulatory inspections from 1992 to 2012 categorized by inspections found in compliance or with one or more deficiencies found. www.health-physics.com

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medical use of radiation producing devices in diagnostic imaging at other facilities (Smith-Bindman et al. 2012) and across the U.S. (NCRP 2009). Fig. 2 displays a dramatic increase in the number of regulatory compliance inspections that occurred over the 20‐y period. This data is compelling because despite an overall reduction in the use of radioactive materials at UTHSCH, it was important to demonstrate that the number of regulatory inspections has actually increased.

DISCUSSION Business prospectuses are created to describe the financial health of an organization so that individuals can make informed investment decisions. Over the years, the business community has reached general consensus on several performance indicators on which investment decisions are generally based, the hallmark example being “price to earnings ratio.” Unfortunately, the radiation safety community suffers from a lack of such generally accepted and recognizable performance indicators, and thus must make an extra effort to demonstrate the value a radiation safety program brings to an organization. For persons unfamiliar with the nuances of radiation safety, a likely assumed consensus indicator of program performance would be health outcomes. But with immediately recognizable radiation-related health outcomes generally lacking in the workplace, the measure is not very useful, so attention may then turn to doses to personnel, serving as a precursor indicator to possible deleterious health effects. But occupational doses in the institutional setting are generally quite low, so the ability to gauge the efficacy of a program’s influence on dose reduction becomes difficult (Gorham et al. 2003). Therefore, attention might be then focused on the results of compliance inspections S156

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as a program performance indicator, but these measures can be subjected to a variety of biases and influences. Given the problems associated with all three of the most likely performance measures, it is incumbent upon the radiation safety community to promote valid indicator measures of its own. Upon compilation of the 20‐y prospectus, it was circulated to the institutional radiation safety committee, and a remarkably consistent set of observations were noted. The consensus observation was that, in spite of a steady growth in the research enterprise, significant reductions can be seen in dosimetry issuance beginning around 1996 and waste disposal costs, but the committee should be attuned to any risks associated to the expansion of use of radiation producing devices. These observations were complemented with remarks about the sound program management practices in place within the unit. The focus of the UTHSCH Radiation Safety Program over the past 20 y has gone from primarily radioactive material use to oversight more equally of both radioactive material use and radiation producing devices uses. For example, in 1992, only the state correspondence regarding the use of radioactive material was included in the monthly Radiation Safety Committee agendas, and contrastingly, in 2012, correspondence with the state regarding x-ray use is routinely included in the monthly committee agendas and certain protocols with x rays and/or lasers are reviewed by the committee as well. The shift in the focus of these Radiation Safety Committee agendas demonstrates a shift in the focus of the program as well from primarily radioactive material use centered to a balance of focus on radioactive material, x-ray and lasers use. Thus a review of committee’s agendas provides evidence of the shift in the radiation safety focus to x-ray producing equipment

and lasers in addition to radioactive material. The prospectus also helped executive leadership understand the professional training needs that existed within the unit. The bulk of the radiation protection program staff’s experience had been with radioactive materials in research labs, but with the declines noted in this area and concurrent expansion in the use of radiation producing devices, a successful argument was made for resources to support training in the areas of x-ray and laser safety. There are many other program indicators that might be captured and displayed. The parameters detailed in this prospectus were chosen in part due to the availability of data for the 20‐y period and experienced gained from the original 10‐y document. Uniform interpretation of data parameters is also important. For example, the number of dosimeters issued could be confused with number of dosimetry program participants, because, in some situations, more than one dosimeter is worn by an individual. So care must be taken to ensure to use of uniform definitions. Other parameters might include regulatory inspection results, laboratory square footage, and numbers of designated radiation workers. Likewise, a myriad of relationship between indicator parameters might be examined. For example, waste disposal costs per square foot of lab space or number of radiation workers might prove interesting. Perhaps the most valuable benefit arising from this effort is the maintenance of the impression of the radiation safety program being managed in a business-like manner. To be able to succinctly communicate what the program does, at a moment’s notice, has demonstrated time and time again the value of the radiation safety program to various stakeholders. A similar approach was used with great success detailing the possession limits of various radionuclides for a

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broad scope radioactive materials license (Emery and McCrary 2003a). The concept of a program prospectus is not limited in its applicability to radiation safety programs. A 10‐y prospectus describing biological safety program activities has been developed with similar success (Emery et al. 2012). The data displayed in Fig. 2 underscores that regulatory agency inspections occur on a regular basis in the radiation safety profession. This is in stark contrast to other health and safety settings where regulatory inspections do not occur with such frequency. As evident from Fig. 2, few inspections over the 20 y period resulted in non-compliance. The increased frequency of inspections is not due to repeated non-compliance as the number of inspections increased even after periods of multiple inspections resulting in no items of noncompliance. Possible reasons for the increase in inspections include the addition of a separate Increased Controls inspection starting in 2007 for UTHSCH, the addition of radiation permitted sites since 2008 and the staffing levels and priorities of the state regulatory agency and their inspectors. The inspectors have indicated a priority on new sites. While inspections are on different intervals by type of authorizations at each site, an overall increase in the number of inspections is clearly evident. The total number of permitted sites for UTHSCH has fluctuated from 10 total permitted sites to 16 total permitted sites over the 20‐y period. By comparing two equal time periods with similar total number of permitted sites, the first 4 y of inspections and the last 4 y of inspections showed an approximate triple increase in the total number of inspections from 6 inspections during 1992–1995 to 19 inspections during 2009–2012. Thus, a prospectus review of compliance may also need to consider the total number of permitted sites as well Operational Radiation Safety

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to show in context the frequency of the inspections. The next evolutionary step in the creation of such summaries would be to benchmark amongst institutions. But for this to occur, consensus must be reached on a set of valid parameters that are truly indicative of program activities. Perhaps through discussions and working groups within professional organizations such as the Health Physics Society, such agreement can serve to ultimately bolster the image of radiation safety programs so that necessary resources can be obtained to ensure the protection of their respective constituencies. Acknowledgments—The authors wish to express their sincere appreciation to the staff of the UTHSCH Radiation Safety Program, both present and past, for their active participation in the assembly of the data used in this project.

REFERENCES American Recovery and Reinvestment Act of 2009. 111. P.L. 5. 123 Stat. 115. 2009 Enacted H.R. 1. 2009. Brauer RL. Safety and health for engineers. New York: Van Nostrand Reinhold; 1990. Emery RJ, Johnston TP, Sprau DD. Simple physical, chemical, and biological safety assessments as part of a routine institutional radiation safety survey program. Health Phys 69:278–280; 1995. Emery RJ, Sawyer RL, Sprau DD. Assessing the service provided by an institutional radiation safety survey program. Health Phys 70: 741–743;1996. Emery RJ, Pollock J, Charlton M. Notices of violation issued to Texas radioactive material licensees inspected in 1995. Health Phys 73: 706–709; 1997. Emery RJ, Savely S. The benefits of actively soliciting worker concerns during routine safety inspections. Professional Safety 42: 36–38; 1997. Emery RJ. Adding value to your radiation protection program. In: Roessler CE. Management and administration of radiation safety programs. Madison, WI: Medical Physics Publishing; 1998: 461–471.

Emery RJ, Charlton MA. Assessing the results of receipt monitoring programs for packages containing radioactive materials. Health Phys 77(Suppl 1):S5–S9; 1999. Emery RJ, Charlton MA, Goodman GR. Texas radiation safety program outcomes as indicated by regulatory compliance activities from 1988 to 1997. Health Phys 78:335–342; 2000. Emery RJ, Gamble RK, Brown BJ. A biological safety program prospectus based on the collection of 10 years of key performance indicator data. Appl Biosaf 17: 19–23; 2012. Emery RJ, McCrary JR. Effectively displaying broad scope sublicensee radioactive material inventory allocations and possession quantities. Health Phys 85(Suppl 1): S39–S41; 2003a. Emery RJ, McCrary JR. A radiation protection program prospectus based on the collection of 10 years of key performance indicator data. Health Phys 85(Suppl 2):S89–S93; 2003b. Gorham RA, Emery RJ, Ford CE, Cooper SP. Statistical validation of a commonly used method for personnel dosimetry issuance determinations Health Phys 84: 260–265; 2003. National Science Foundation, National Center for Science and Engineering Statistics. Two NSF surveys on R&D document varied relationships between business and academia. Arlington, VA: NSF; NSF 13‐333; 2013. National Council on Radiation Protection and Measurements. Ionizing radiation exposures of the population of the United States. Bethesda, MD: NCRP; Report No. 160; 2009. Smith-Bindman R, Miglioretti DL, Johnson E, Lee C, Feigelson HS, Flynn M, Greenlee RT, Kruger RL, Hornbrook MC, Roblin D, Solberg LI, Vanneman N, Weinmann S, Williams AE. Use of diagnostic imaging studies and associated radiation exposure for patients enrolled in large integrated health systems, 1996–2010. JAMA 307: 2400–2409;2012. U.S. Nuclear Regulatory Commission. Standards for protection against radiation. Washington, DC: U.S. Government Printing Office; 10 CFR Part 20; 1992. Webster’s 9th New Collegiate Dictionary. Springfield, MA: MerriamWebster Inc.; 1990.

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An updated radiation protection program prospectus based on 20 years of data describing program drivers and activities.

In 1992, the University of Texas Health Science Center at Houston (UTHSCH) Radiation Safety Program began assembling data on a monthly basis that desc...
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