Create a Safe Job Procedure for N.O.R.M.S.
Naturally Occurring Radioactive Material (NORM/N.O.R.M.S.) Handling
Document Number: [SWP-NUMBER]
Revision Date: [DATE]
Next Review Date: [NEXT REVIEW DATE]
Department: [DEPARTMENT NAME]
1. Scope
This Safe Work Procedure applies to the identification, handling, temporary storage, contamination control, decontamination, monitoring, packaging, transport preparation, and disposal of naturally occurring radioactive material (NORM/N.O.R.M.S.) and NORM-contaminated equipment, dust, residues, and waste generated during industrial activities. It is intended for workplaces where NORM may be encountered, including mineral extraction and processing, metal recycling, waste management, phosphate fertilizer production, forestry products and thermal electricity facilities, tunneling and underground workings, and water treatment facilities using sorptive media or ion-exchange resins. The procedure is limited to routine NORM handling and contamination-control activities performed by trained personnel; higher-risk tasks such as major decontamination, source recovery, unusual contamination events, or work involving elevated radiation levels must only be performed by personnel with appropriate radiation safety training and authorization. This procedure does not replace site-specific radiation protection programs, regulatory requirements, or emergency response plans, and it must be used together with applicable permits, monitoring programs, and waste-disposal requirements.
2. Definitions
Naturally Occurring Radioactive Material (NORM) Radioactive material containing naturally occurring radionuclides such as uranium, thorium, potassium, and their decay products. NORM may be present at low levels in the earth’s crust but can become concentrated through industrial processing, increasing exposure potential. [1] [1]
Contamination The presence of radioactive material on surfaces, equipment, clothing, skin, or in the work area where it can be spread by contact, dust generation, or improper handling. Contamination control focuses on preventing spread and removing radioactive residues safely. [3] [6]
Occupational exposure Exposure received by a worker in the course of employment where duties involve radiation or radioactive material, including work in restricted areas or areas where NORM contamination may be present. [2]
Personnel monitoring The assessment of a worker’s radiation dose using wearable monitoring devices, bioassay, or survey data to verify exposure control and compliance with dose limits. [2]
ALARA A radiation protection principle meaning exposures should be kept as low as reasonably achievable by using time, distance, shielding, contamination control, and work planning. [3] [3]
3. Responsibilities
3.1 Supervisors
- Ensure a pre-job hazard assessment is completed before NORM work begins, including identification of likely contamination sources, exposure pathways, required controls, and emergency arrangements. Supervisors must verify that the work plan reflects the actual site conditions and that the task is stopped if conditions change or if unexpected contamination is discovered. [14] [13]
- Assign only trained and authorized workers to handle NORM, contaminated equipment, or contaminated waste. Supervisors must ensure workers understand radiation hazards, contamination controls, decontamination methods, and the limits of their authorization. [1] [3]
- Ensure radiation surveys, contamination checks, and personnel monitoring are performed as required, and that calibrated survey instruments and dosimetry are available before work starts. Supervisors must review results and take immediate corrective action if readings indicate elevated exposure or contamination. [6] [6]
- Maintain controlled access to NORM storage and work areas, enforce housekeeping and dust suppression measures, and ensure contaminated materials are packaged, labeled, and transferred to authorized disposal or processing facilities without stockpiling. [1] [1] [7]
- Ensure incidents, abnormal survey results, contamination events, damaged containers, or suspected overexposures are reported immediately and investigated, and that corrective actions are documented and communicated to the workforce. [4] [11]
3.2 Workers
- Follow all radiation safety instructions, site rules, and permit conditions; attend required training and pre-job briefings; and stop work immediately if controls are missing, damaged, or ineffective. [1] [13]
- Wear the required PPE correctly, keep it clean and serviceable, and do not remove PPE until contamination checks confirm it is safe to do so. Workers must not eat, drink, smoke, chew, or store food in NORM-controlled areas. [1] [1]
- Use dust-minimizing work practices, maintain distance from the source where practical, and minimize time spent in contaminated areas. Workers must avoid cutting, grinding, polishing, or other activities that can generate airborne contamination unless specifically authorized and controlled. [1] [1] [1]
- Report damaged containers, unusual dust, elevated survey readings, contamination on skin or clothing, spills, leaks, or any suspected exposure immediately to the supervisor and follow decontamination and emergency instructions without delay. [6] [7]
- Cooperate with personnel monitoring, contamination surveys, bioassay requirements if assigned, and recordkeeping requirements, including returning dosimeters on schedule and participating in post-job contamination checks. [6] [6]
3.3 Health and Safety Representative
- Participate in hazard assessments, workplace inspections, and review of control measures to verify that radiation protection practices are effective and practical for the task being performed. [12] [13]
- Review incident trends, near misses, contamination events, and monitoring results to identify recurring weaknesses in work planning, housekeeping, PPE selection, or decontamination practices. [11] [11]
- Support worker consultation, reinforce reporting expectations, and verify that corrective actions are implemented and communicated after incidents or abnormal survey findings. [5] [11]
4. Potential Hazards and Risks
| Hazard | Risk | Control Measures |
|---|---|---|
| Airborne NORM dust generated during handling, cutting, grinding, cleaning, or transfer of contaminated material [1] [1] [3] | Inhalation of radioactive dust leading to internal exposure, contamination of respiratory tract, and increased long-term cancer risk. | Eliminate or minimize dust-generating activities where possible. Use wet methods, local containment, and controlled handling techniques. Prohibit cutting, grinding, and polishing unless specifically authorized and controlled. Wear appropriate respiratory protection when engineering and administrative controls cannot adequately prevent inhalation exposure. |
| Contaminated surfaces, tools, clothing, and equipment [1] [1] [7] | Spread of radioactive contamination to workers, vehicles, clean areas, and the environment. | Establish designated contaminated zones and controlled access. Inspect and survey equipment before removal from the work area. Decontaminate equipment and surfaces using approved methods, and check all workers for contamination before leaving the work area. Package and label contaminated items for authorized disposal or storage. |
| External radiation exposure from concentrated NORM residues, scale, sludge, or contaminated equipment [3] [3] [9] | Increased occupational dose from prolonged proximity to radioactive material. | Apply ALARA principles by minimizing time near the source, maximizing distance, and using shielding where appropriate. Restrict access to the work area, post warning signs where required, and use calibrated survey instruments to verify dose rates before and during work. |
| Improper storage or unsecured transport of NORM-contaminated material [7] [7] | Loss of control, unauthorized access, accidental release, tampering, or contamination during transport. | Store radioactive material in locked, physically secured containers or designated storage areas. Secure transport packages in vehicles to prevent movement or unauthorized removal. Ensure packages are labeled, marked, and accompanied by appropriate shipping papers when transport is required. |
| Inadequate personnel monitoring or failure to detect contamination before leaving the work area [6] [6] [1] | Undetected exposure or spread of contamination beyond the controlled area. | Issue and require personal dosimetry where applicable, perform routine contamination surveys, and conduct exit contamination checks before workers leave the controlled area. Maintain records of monitoring results and investigate abnormal readings immediately. |
| Waste accumulation and poor disposal practices [1] [1] | Stockpiling of contaminated waste, increased exposure, and environmental release. | Segregate NORM waste, label it clearly, and transfer it promptly to a facility authorized to accept contaminated materials. Maintain waste records and avoid unnecessary accumulation of contaminated materials on site. |
| Damaged sealed source, ruptured container, or unexpected high radiation reading [6] [7] | Potential acute exposure, contamination spread, and need for emergency response. | Stop work, isolate the area, notify the supervisor, and prevent entry. Use trained radiation safety personnel to assess the scene, determine contamination boundaries, and implement decontamination and protective measures. Do not attempt unauthorized repairs or source manipulation. |
5. Personal Protective Equipment (PPE)
Personal protective equipment is the last line of defense and must be selected to match the contamination, inhalation, and splash hazards identified in the job hazard analysis. PPE does not replace engineering controls, contamination control, or good work practices; it must be used together with exposure minimization, controlled access, and monitoring.
- Impermeable Coveralls or Disposable Protective Clothing: Wear impermeable or disposable coveralls that provide full-body coverage and reduce the transfer of radioactive dust or residues to personal clothing and skin. Clothing should fit properly, allow safe movement, and be removed as contaminated waste or decontaminated according to site procedures after use. [1]
- Use disposable garments when contamination is expected to be difficult to remove.
- Inspect seams, closures, and cuffs before use.
- Remove clothing carefully to avoid spreading contamination.
- Chemical-Resistant Boots or Boot Covers: Use boots or boot covers that are resistant to contamination and easy to decontaminate or dispose of. Footwear must prevent tracking radioactive material out of the controlled area and should be dedicated to the work zone when practical. [1]
- Select slip-resistant soles suitable for the work surface.
- Inspect for tears, cracks, or contamination before entry and before exit.
- Decontaminate or dispose of footwear in accordance with site rules.
- Protective Gloves: Wear gloves appropriate to the contamination and chemical conditions present. Gloves should provide a secure wrist seal, maintain dexterity for handling tools and samples, and be changed immediately if torn, heavily contaminated, or compromised. [1]
- Use double-gloving where contamination potential is elevated.
- Avoid touching clean surfaces with contaminated gloves.
- Remove gloves before touching personal items or controls outside the work zone.
- Protective Eyewear or Face Protection: Use protective eyewear or face protection to prevent contamination of the eyes and face during dusty work, decontamination, or transfer operations. Eye protection should fit securely and be compatible with respirators and other PPE. [1]
- Select sealed goggles where splash or dust exposure is likely.
- Use face shields when there is a risk of splatter during decontamination.
- Clean or dispose of eye protection after use if contaminated.
- Respiratory Protection: Use respiratory protection when airborne contamination cannot be adequately controlled by engineering or work-practice controls. Respiratory protection must be selected, fitted, and used in accordance with the site respiratory protection program and the contamination hazard present. Negative-pressure, positive-pressure, or supplied-air devices may be required depending on the exposure scenario and regulatory requirements. [1]
[2]
[8]
- Perform fit testing and user seal checks before use.
- Do not use a respirator with facial hair or damaged seals.
- Remove and replace filters or cartridges according to the program and contamination conditions.
- Personal Dosimeter: Wear assigned personnel monitoring equipment whenever required by the radiation protection program. Dosimeters must be worn by one person only, kept in the correct location on the body, and returned for processing on schedule so that occupational exposure can be tracked accurately. [6]
[2]
- Do not share dosimeters.
- Store dosimeters away from heat, contamination, and radiation sources when not in use.
- Report lost, damaged, or unreadable dosimeters immediately.
Inspect PPE before each use for tears, punctures, degraded seals, contamination, missing components, and fit issues. Replace disposable PPE when contaminated or damaged, and clean reusable PPE only using approved decontamination methods. Maintain PPE in a sanitary and reliable condition, and remove from service any item that cannot be effectively decontaminated or repaired. [13] [1]
6. Equipment and Tools
Equipment and monitoring devices used for NORM work must be suitable for the contamination level, calibrated where required, and inspected before use. Defective or uncalibrated equipment must not be used because it can lead to missed contamination, inaccurate dose assessment, or uncontrolled exposure.
- Calibrated Radiation Survey Meter: Use a calibrated and operable survey meter capable of detecting beta and gamma radiation to assess work areas, containers, tools, and vehicles before, during, and after NORM handling. The instrument must be suitable for the expected dose range and contamination conditions. [7]
[7]
- Verify calibration status before use.
- Check battery condition and response with a source check if required by site procedure.
- Remove from service if readings are unstable or the instrument fails a functional check.
- Contamination Survey Supplies: Use wipes, swipe media, sample containers, labels, and documentation forms to perform contamination surveys and record results. Supplies must be clean, compatible with the material being sampled, and handled to prevent cross-contamination. [9]
- Use separate materials for clean and contaminated areas.
- Label samples immediately after collection.
- Follow chain-of-custody or site documentation requirements where applicable.
- Designated Storage Containers or Waste Packages: Use locked, physically secured containers or packages for temporary storage and transfer of NORM-contaminated materials and waste. Containers must be compatible with the waste form, clearly labeled, and maintained to prevent tampering, leakage, or unauthorized access. [7]
[7]
- Inspect closures, seals, and labels before use.
- Do not overfill containers.
- Keep incompatible materials segregated.
- Remote Handling Tools: Use remote handling tools where practical to increase distance from contaminated material and reduce direct contact. Tools must be appropriate for the load, inspected for damage, and kept clean to avoid spreading contamination. [6]
[3]
- Verify handles, grips, and moving parts before use.
- Do not use improvised tools for radioactive material handling.
- Decontaminate tools after use or segregate them as contaminated equipment.
- Decontamination Equipment and Materials: Provide approved cleaning materials, absorbents, containment supplies, and waste bags or drums for controlled decontamination of surfaces, tools, and PPE. Decontamination materials must be selected to avoid spreading contamination and must be disposed of as radioactive waste when contaminated. [1]
[6]
- Use only approved cleaning agents and methods.
- Contain runoff and residues.
- Survey the area after decontamination to confirm effectiveness.
Inspect survey meters, remote handling tools, storage containers, and decontamination equipment before each use and at the frequency required by the radiation protection program. Remove defective equipment from service immediately, document the defect and repair, and do not return the item to use until it is verified safe and functional. Maintain calibration records, inspection logs, and maintenance records for the required retention period. [7] [7]
7. Pre-Job Requirements
7.1 Training and Competency
Training and Competency: Only workers who have received radiation safety training appropriate to the task may handle NORM or contaminated materials. Training must cover the difference between radiation and contamination, internal and external exposure, biological effects, ALARA principles, survey instrument use, contamination control, emergency actions, and waste handling. Workers assigned to higher-risk or nonroutine tasks must receive task-specific instruction and demonstrate competence before working independently. [3] [1]
7.2 Pre-Job Briefing
Pre-Job Briefing: Conduct a documented pre-job briefing before each NORM task to review the scope of work, identified hazards, control measures, PPE, monitoring requirements, contamination boundaries, waste handling, emergency actions, and stop-work authority. The briefing must confirm that workers understand the work sequence, communication methods, and the steps the employer has taken to protect them from exposure. [1] [13]
7.3 Work Area Preparation
Work Area Preparation: Prepare the work area by establishing controlled access, posting warning signs where required, segregating clean and contaminated zones, and arranging containers for waste and contaminated tools. Verify that ventilation, dust suppression, lighting, and housekeeping arrangements are adequate for the task. Remove unnecessary personnel and materials from the area before work begins. [1] [1] [9]
8. Safe Work Procedure Steps
- 1. Confirm Authorization and Review the Job Plan: Verify that the task is authorized, that the crew is trained for NORM work, and that the work plan matches current site conditions. Review the hazard assessment, required controls, PPE, monitoring requirements, waste routes, and emergency actions before starting. If the task involves unusual contamination, elevated readings, or nonroutine work, stop and obtain radiation safety direction before proceeding. [1]
[13]
- Confirm scope, boundaries, and stop-work authority.
- Review any permits, access restrictions, and disposal requirements.
- Ensure all required equipment and PPE are available and serviceable.
- 2. Establish the Controlled Area: Set up the work zone so that contaminated material is isolated from clean areas and unauthorized entry is prevented. Post warning signs where required, define entry and exit points, and place containers, survey instruments, and decontamination supplies at the boundary. Keep food, drink, and smoking materials out of the area at all times. [1]
[1]
- Restrict access to essential personnel only.
- Use barriers, tape, cones, or other physical controls as needed.
- Maintain clear housekeeping to reduce spread of dust and residues.
- 3. Inspect PPE, Tools, and Monitoring Devices: Before entering the work area, inspect all PPE, survey meters, remote handling tools, containers, and decontamination supplies. Confirm that survey instruments are calibrated and operable, dosimeters are assigned correctly, and any damaged or defective equipment has been removed from service. Do not begin work until all required items are ready and verified. [7]
[6]
[7]
- Check PPE for tears, degraded seals, and fit issues.
- Verify survey meter function and calibration status.
- Confirm dosimeter assignment and wear location.
- 4. Don Required PPE and Perform Entry Controls: Put on the required PPE before entering the controlled area and ensure all closures, seals, and respirator checks are completed. Use respiratory protection when airborne contamination is possible or when dust cannot be adequately controlled by other means. Enter the work area only after the supervisor confirms that controls are in place and the crew understands the task sequence. [1]
[2]
- Perform respirator seal checks or fit checks as required.
- Avoid touching clean surfaces with contaminated gloves or clothing.
- Keep PPE on until exit contamination checks are complete.
- 5. Handle NORM Using Dust-Control and ALARA Practices: Handle material carefully to avoid generating dust or spreading contamination. Use wet methods, enclosed transfer methods, or remote handling tools where practical. Keep time in the contaminated area as short as possible, maximize distance from the source, and use shielding if appropriate. Do not cut, grind, polish, or otherwise disturb material unless the activity has been specifically assessed and controlled. [1]
[1]
[1]
[3]
- Move slowly and deliberately to avoid spills and airborne release.
- Keep containers closed when not actively transferring material.
- Use shielding only when it is suitable for the material and task.
- 6. Perform Radiation and Contamination Monitoring: Conduct surveys of the work area, tools, containers, and personnel at the frequency required by the job plan and whenever conditions change. Use calibrated instruments to identify elevated radiation levels and contamination. Record readings, compare them to expected background or site action levels, and stop work if abnormal results are found. [6]
[1]
[1]
- Survey before work, during work as needed, and after completion.
- Check the exterior of containers and transport packages before movement.
- Monitor workers before they leave the controlled area.
- 7. Package, Label, and Segregate Contaminated Material: Place contaminated material, disposable PPE, wipes, absorbents, and removed equipment into designated containers or waste packages. Keep containers closed, labeled, and physically secured. Segregate contaminated items from clean materials and prevent overfilling or leakage. Prepare shipping or transfer documentation when material is moved off site. [7]
[7]
- Use only approved containers for the waste form.
- Label containers clearly as radioactive or contaminated material as required by site rules.
- Do not mix incompatible waste streams unless authorized.
- 8. Decontaminate Personnel, Tools, and Work Surfaces: After the task is complete, decontaminate tools, equipment, and work surfaces using approved methods. Remove contamination from personnel in the designated decontamination area and re-survey to confirm effectiveness. If contamination cannot be removed safely, isolate the item, label it, and treat it as contaminated waste or contaminated equipment. [1]
[6]
- Use approved cleaning methods that do not spread contamination.
- Collect residues and cleaning materials as radioactive waste.
- Repeat surveys until the area meets release criteria or supervisor direction.
- 9. Remove PPE and Exit the Controlled Area: Remove PPE in the correct sequence to avoid self-contamination and spread of radioactive material. Perform final contamination checks on hands, clothing, footwear, and any reusable equipment before leaving the controlled area. Dispose of single-use PPE as contaminated waste and store reusable items for decontamination or controlled reuse. [1]
[13]
- Remove outer gloves and disposable items first, unless site procedure specifies otherwise.
- Avoid touching the face, hair, or personal items during doffing.
- Wash hands and exposed skin after exit if contamination controls require it.
- 10. Complete Records and Report Findings: Document survey results, contamination checks, waste quantities, equipment defects, dosimeter issues, and any unusual conditions encountered during the job. Report abnormal readings, contamination events, spills, damaged containers, or suspected exposures immediately through the site reporting process. Retain records according to the radiation protection program and regulatory requirements. [6]
[11]
[7]
- Record date, location, personnel involved, and key readings.
- Note any corrective actions taken during the job.
- Escalate unresolved issues to radiation safety personnel.
9. Precautions and Safety Measures
- Do not eat, drink, smoke, chew, or store food in NORM-controlled areas. - Provide designated clean areas for breaks and ensure workers wash hands before entering those areas. [1]
- Minimize time in contaminated areas and maximize distance from the source whenever practical. - Plan the work so that tools, containers, and personnel are staged efficiently and unnecessary re-entry is avoided. [1] [1]
- Use shielding where appropriate to reduce dose rates from concentrated material. - Only use shielding that is suitable for the material, geometry, and task, and verify that it does not create additional handling hazards. [1] [3]
- Prevent dust generation and airborne spread of contamination. - Avoid cutting, grinding, polishing, dry sweeping, or compressed-air cleaning unless specifically authorized and controlled by the radiation protection program. [1]
- Keep contaminated materials and waste in a designated, access-controlled area until disposal or transfer. - Use clear labels, secure storage, and routine housekeeping to prevent accumulation and unauthorized access. [1] [7]
10. Emergency Procedures
10.1 General Emergency Response
If an emergency occurs, stop work immediately, warn nearby personnel, isolate the area, and notify the supervisor and radiation safety personnel. Do not attempt cleanup or repair unless you are trained and authorized to do so. Use the site emergency plan to determine evacuation, medical response, contamination control, and notification requirements. If contamination may have spread, prevent entry and establish boundaries until trained personnel complete the assessment. [6] [6]
10.2 Specific Emergency Scenarios
- Suspected overexposure or unexpectedly high radiation reading: Stop the task, withdraw personnel from the immediate area, and prevent re-entry. Notify the supervisor and radiation safety personnel, then perform a controlled survey to confirm the reading and identify the source. Review dosimetry and work conditions, and do not resume work until the hazard is understood and controls are corrected. [1] [3]
- Contamination on skin, clothing, or personal items: Stop work, avoid spreading contamination, and move to the designated decontamination area. Remove contaminated outer clothing and follow approved decontamination steps for skin and equipment. Re-survey the person and items before allowing them to leave the controlled area. [1] [6]
- Spill, leak, or damaged container with visible contamination: Isolate the area, stop movement of material, and prevent dust generation. Notify the supervisor immediately and have trained radiation safety personnel assess the extent of contamination using suitable survey instruments. Collect and package contaminated materials using approved methods and send them to authorized disposal or processing facilities. [1] [1]
- Fire, explosion, or other event affecting stored NORM waste: Evacuate the area if conditions are unsafe, notify emergency responders, and inform them that radioactive material may be involved. Do not disturb damaged containers unless directed by trained radiation safety personnel. After the scene is stabilized, perform contamination surveys and manage residues as radioactive waste. [7] [10]
10.3 Emergency Contact Information
Emergency contact information, site radiation safety contacts, medical response contacts, and regulatory notification numbers must be inserted by the employer or site administrator in the final controlled document.
Approved by: [NAME AND POSITION]
Date: [APPROVAL DATE]
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References
Page links are approximateOSH Enforcement Procedures | CPL 02-02-073 - Inspection Procedures for 29 CFR 1910.120 and 1926.65, Paragraph (q): Emergency Response to Hazardous Substance Releases
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