Cesium irradiators and security

[PeterD]

We have just been informed in our blood bank that we need to head to the local police department to be fingerprinted due to security issues involving Cesium irradiators. The manager was not very forthcoming with details yet but insinuated it was a homeland security issue. When questioned if it were required to maintain employment, the answer was yes. Does anyone have experience with this issue, who is requiring it, what if any options are open to blood bankers, and what other legal issues are involved. I am reluctant to submit to allowing this and other personal information to be placed into any sort of database, no matter who is making the request. Are there any choices in this matter and where can reliable information be obtained to what purpose this will serve?

[dmpollock]

The requirement for fingerprinting comes from NRC is mentioned in excerpt below from the AABB website. I would recommend compliance. You might be able to go during working hours when you get fingerprinted, since it is a job requirement.

You also can find a reference at http://www.nrc.gov/security/byproduct/fingerprinting-workshop-slides.pdf

Issue 4 – Additional Requirements for Enhanced Security of CsCl Sources

It was noted during the workshop that the NRC has mandated increased security measures to reduce homeland security risk. The increased security measures include, but are not limited to, performing a trustworthy and reliability review and fingerprinting for unescorted access to secure areas. In addition, information technology personnel must undergo the same security measures because they are the staff that controls access to secure areas. The NRC has been collaborating with several manufacturers on hardening efforts that would increase the amount of time for unauthorized access to the source material; a pilot program to achieve a goal of greater than 60 minutes is currently under way. A representative from FDA/CDRH indicated that the proposed device hardening efforts would not impact the device’s 510(k) status.

[PeterD]

Thanks dmpollock for your response. I had found the above information online shortly after posting my question. It would seem that compliance is compulsory as long as the institution maintains a CsCl source irradiator.

Since increased security is obviously the objective, my question still remains how precisely does fingerprinting of people with routine access achieve this goal. I would assume background checking is part of this process, but what other purposes does it provide, if any? The requirement is clear, the practice is less so.

Interesting times we live in. Thanks again.

[Cliff]

I want to remind anyone who replies to this and any other irradiator security posts, that I monitor all of these very closely and will edit / delete them if needed.

Why would we need to do that?

I have been contacted by the NRC about posts they felt revealed security measures that were in place, and might alert "others" as to what to watch out for.

So, what not to post: any measures that your facility has taken to protect the physical source - feel free to vent your frustrations about the foolishness of these requirements and there amazing lack of a true ability to secure the country. If you wish to discuss how this is a waste of healthcare dollars and can't see how this is helping anyone, again feel free.

During an inspection of a facility I work at, I had an inspector ask what we would do if "someone" rolled a grenade into the lab. I just stood there and couldn't respond.

[John C. Staley]

Cliff, you should have told the inspector that if the grenade was rolled in during an inspection you would throw the inspector on it.

[Franklyn]

My facility has required fingerprints and background checks on all employees for quite a while now, but the fingerprints are obtained electronically and processed by the state. In this case, the fingerprinting is part of an FBI background check, which is somehow different than that performed by the state government. The FBI does not yet obtain fingerprints electronically, they still do them via the old fashioned paper and ink method and then scan those cards in to the database. So, your tax dollars at work is why you need to get your fingers dirty in order to work where you have unrestricted access to any kind of radioactive source.

[mhc]

My frustration with this requirement is that because it was not required "pre-hire", I'm having to cajole, remind, harass, etc. my staff to get this done. I even had an officer on site for several fingerprinting sessions and I still have outstanding staff, including a few who have to have theirs re-done because the FBI found them to be illegible. All this for what?

[Cliff]

Cliff, you should have told the inspector that if the grenade was rolled in during an inspection you would throw the inspector on it.

Hmm, I try not to make bad situations worse.

[Cliff]

My facility has required fingerprints and background checks on all employees for quite a while now, but the fingerprints are obtained electronically and processed by the state. In this case, the fingerprinting is part of an FBI background check, which is somehow different than that performed by the state government. The FBI does not yet obtain fingerprints electronically, they still do them via the old fashioned paper and ink method and then scan those cards in to the database. So, your tax dollars at work is why you need to get your fingers dirty in order to work where you have unrestricted access to any kind of radioactive source.

Hi Franklyn,

Are you sure about the FBI not accepting fingerprints electronically? My facility purchased an electronic scanner and software to submit directly to the FBI. The software is pretty sophisticated, I don't think we have any staff that need to be redone.

[PeterD]

I am glad to hear that some others find this subject a source of frustration and that some others have questions as to the effectiveness of it all.

I too see compliance as a difficulty. In my situation, I am surprised at the lack of preparation of our staff in terms of basic information about the program. I think if we had a greater sense of our own security that may be at stake, the specific reasons it is being imposed, and how our personal information will be used and protected, we may feel more at ease with the process. Instead the whole thing is shrouded in mystery. I fail to understand why some basic specifics of the program in written form could not have been provided. We have not been able to ask any questions and receive any information other than shear logistics of getting it done. Since it seems to be an important issue to the NRC one would think that they would like to get everyone it effects on board from the front. It would be great to have somebody in authority available to answer basic questions that come up. However it also appears that that is not part of the plan maybe even by design.

Thanks all for your thoughts and information.

[paulnb]

I'm sure we would breath easier if the government would fund the replacement of our Cesium irradiators with X-Ray source irradiators. The cost may seem staggering, but in relationship to what is being spent on increased security measures, I'll bet it's not that bad at all. Certainly less that the cost of a stealth aircraft.

[sgoertzen]

There is so much more involved than just getting your staff fingerprinted. Carefully read the NRC Order EA-05-090 from 2005 when this all began. Then add to it the NRC Order EA-07-305 dated December 5, 2007. There are pages and pages of instructions on the security program you must create. Someone at your institution (whoever "owns" your radioactive materials license) received both of these letters (or your State's version of these same orders if you live in an "Agreement State"). Too bad they didn't take the required actions when they got the letters, because now you will be scrambling.

The fingerprints with the FBI is so that they can compare them with their list of possible terrorists. The FBI assured us that our fingerprints do not get "added" to this list. You must also do criminal background checks, and have a sophisticated program (written in policy) whereby your appointed Trustworthy & Reliability Official deems people either acceptable or not acceptable to have unescorted access to your irradiator. We formed a team to work on the whole thing that includes the blood bank supervisor, the lab manager, the hospital legal counsel, the HR director, the HR recruitment manager, our executive director, our security director, and our radiation safety officer (and you also must include your local law enforcement). Also, you must further secure physical access to your irradiator. Its been a rather large project. Apparently, non-compliance is not something you want to experience when they come to inspect you. Good luck!

[bbville]

This is truly not something you want to be out of compliance with. We pared down the list of personel who were fingerprinted (it does cost about $36 per person), but have someone in the lab at all times with unescorted access authorization. We also had a hospital employee do the fingerprinting (he is a fromer police officer). One of our employees had to be redone 3 times as she has no ridges evidently. <some content removed> We had to add 'trustworthy and reliable' to job descriptions. <some content removed>

<some content removed>

Remember that just because someone has not been fingerprinted does not mean they cannot use the irradiator. They just have to be let into the area by someone on the 'list'.

Edited October 24, 2008 by Cliff
Please do not post specific secutiy infrmation

[KECIA]

Hi I work at a childrens hospital and we not only had to go through a background check when I first started but just this summer had to be fingerprinted because we have 2 irradiators and we have the hooked up to security.

[Franklyn]

Are you sure about the FBI not accepting fingerprints electronically?

The FBI is "in the process of converting to an electronic system." We had to work with our local FBI office and they, at least, had no means to accommodate us electronically. We have a fellow on site with the paper cards and ink as recently as October.

My facility has a scanner already, we just were not permitted to use it.

[David]

Our county sheriff's office did ours at no charge and did it electronically.

[Franklyn]

You guys are all making me jealous.

We are in Chicago and, evidently, we are still restricted to stone knives and bearskins when it comes to FBI fingerprints. Luckily, it wasn't too hard to get the ink off of my fingers when we were finished :tongue:

[adiescast]

My HR people indicated that we have other jobs in the hospital system that require the same or higher level of security. They already have a process in place for dealing with this. We just had the guy come in and print everybody in a couple of sessions. No one complained or caused problems. The biggest questions we dealt with were who had to be the Trustworthiness and Reliability Officer and who had to pay the $36 per person fee.

The whole thing seems ridiculous, but then again, who wouldn't have said it is ridiculous to highjack an airplane and use it to destroy a building before 9/11/01? (No details here, Cliff. I wouldn't want to have to kill anyone!) <comments by Cliff - Sorry, I disagree and have removed security details>

Edited November 5, 2008 by Cliff
Please do not post specific secutiy infrmation

[OPUS104]

Hey cliff, We were given many outlandish examples ( we were the first in east TN to be inspected), but my 2 favorites were....What if they come running in with C-4 wrapped around themselves and blow up against the irradiator( to which I said "then none of what your saying will matter" and what if they back a dump truck through the window/wall and hook a chain to it and drag it away (I gave same repsonse). Too funny talking to this guy. We have not had a compliance problem with present personel as we gave them a reasonable dead-line and oppurtunity to do it and said "have it done or stay home".....worked rather well

[bmarotto]

When our inspector said someone could use a screwdriver to take the irradiator apart and walk off with the source, our radiation safety officer explained that the person would have rather quick central nervous system collapse. The inspector did not miss a beat and said "they work in teams and one passes to the next until they get outside to the guy with a barrel full of concrete and drop it in". Like Cliff, I was speechless.

Anyway, all of us in Blood Bank as well as all security guards have been fingerprinted. I did not have any issues with staff complying.

[gnixon]

Re. "When our inspector said someone could use a screwdriver to take the irradiator apart and walk off with the source"

Your inspector clearly has no concept of how these machines are fabricated, where the sources are located, and of the rather extreme measures that would be required in order to gain access to them. This kind of misinformation speaks directly to their level of competence (or rather, incompetence). They should probably be reported to the state or national authority (as appropriate) because nobody needs this would-be "Chicken Little" running around. Certainly, it would prove a public service if you were to "out" him. I would recommend that the inspector NOT be retrained, however, because it would only serve to make them (marginally) more dangerous.

Best regards,

Grant

When our inspector said someone could use a screwdriver to take the irradiator apart and walk off with the source, our radiation safety officer explained that the person would have rather quick central nervous system collapse. The inspector did not miss a beat and said "they work in teams and one passes to the next until they get outside to the guy with a barrel full of concrete and drop it in". Like Cliff, I was speechless.

Anyway, all of us in Blood Bank as well as all security guards have been fingerprinted. I did not have any issues with staff complying.

[gnixon]

I'm sure we would breath easier if the government would fund the replacement of our Cesium irradiators with X-Ray source irradiators. The cost may seem staggering, but in relationship to what is being spent on increased security measures, I'll bet it's not that bad at all. Certainly less that the cost of a stealth aircraft.

The current direction is that the govenment intends to fund a source hardening retrofit for Cs-137 irradiators whereby the sources will be rendered even more inaccessible than they already are. To this end, some beta sites have already been retrofitted in this way. Further, there are efforts underway to manufacture less dispersible physical forms Cs-137 material that would also prove less soluble. The latter efforts will likely take ~5 years to complete.

Cesium irradiators have historically proven to be more reliable (and will ALWAYS be more reliable), cost less to maintain (x-ray tubes and power supplies are expensive consumables), and have a higher throughput that x-ray based units. As such, if your site has a critical need for just-in-time irradiated blood, then, given the current state of the art, cesium units continue to be the way to go.

Grant

[MJDrew]

I hadn't had the chance to visit for awhile, but when it comes to this, don't get me started! :mad:

In response to the questions re: electronic fingerprinting, I think anyone in the healthcare field needs to be fingerprinted electronically. Being the compulsive handwashers we are , many if not all of us have poor fingerprints for the manual method. We actually rub them off!! This just adds insult to dirty fingers when asked to do this multiple times with an outmoded technology! So insist on the electronic method if it's at all possible.

Just a hint, although it might not be doable for large health systems or departments, it could work for an individual: Most PIs (private investigators) have the electronic method readily available and are more than familiar with the issues health care folks face. I found this out by accident when having to be fingerprinted for multiple new state medical licenses for my new job, as the local PD here in Portland refused to do this(??). What possible benefit 6 different forays into the same FBI database has for the states licensing me, I cannot say, but as has been said here, this is a new world we live in.

As a good friend said after I had related the above tale of woe: "You could have had a second career as a criminal with your lack of fingerprints!"