10 CFR 34.2 (b) and (c) - Definitions of Radiographer and Radiographer's Assistant
HPPOS-187 PDR-9111210293
Title: 10 CFR 34.2 (b) and (c) - Definitions of
Radiographer and Radiographer's Assistant
See the excerpt from the NRC Inspection Manual entitled as
above and dated June 13, 1974. This section states that a
radiographer must be physically present at the site when
radiography is taking place. Any individual who assists a
radiographer by manipulating devices or instruments acts as
a radiographer's assistant and must meet the requirements
of 10 CFR 34.31 (b).
As specified in 10 CFR 34.2 (b), a "radiographer" means any
individual who performs or who, in attendance at the site
where the sealed source or sources are being used,
personally supervises radiographic operations and is
responsible to the licensee for assuring compliance with
the requirements of the Commission's regulations and the
conditions of the license. 10 CFR 34.2 (c) defines a
"radiographer's assistant" as any individual who, under the
personal supervision of a radiographer, uses radiographic
exposure devices, sealed sources or related handling tools,
or radiation survey instruments in radiography.
Licensing has construed (with OGC concurrence) these
definitions to mean that a radiographer must be physically
present at the site where the radiography is taking place.
This does not mean in the vicinity of or near the site of
exposure, but the site where the actual radiographic
operation is being conducted. A radio-grapher's assistant
may not perform any operation unless the radiographer is
physically present to personally supervise the operation.
1. The duties and responsibilities of the radiographer
may not be delegated to a radiographer's assistant, and
2. Any individual who assists a radiographer by
manipulating radiographic exposure devices, sealed sources,
related handling tools, or survey instruments is acting in
the capacity of a radiographer's assistant and must meet
the requirements of 10 CFR 34.31 (b).
It is possible for a radiographer to supervise the
activities of more than one radiographer's assistant. For
example, an in-plant operation with more than one
radiographic cell could involve a number of radiographers'
assistants and only one radiographer. In such a situation,
the radiographer would need to be physically present while
any manipulation of the exposure devices or survey
instruments were being performed.
It is usually the intent of radiographic licensees to
qualify individuals to act as radiographers. The vast
majority of programs do not have "career" radiographers'
assistants. The designation of radiographer's assistant is
usually intended for a person being trained as a
radiographer and who must meet the requirements to act as a
radiographer's assistant in order to gain the necessary
experience to qualify as a radiographer.
Regulatory references: 10 CFR 34.2, 10 CFR 34.31
Subject codes: 1.3
Applicability: Byproduct Material