permits from the appropriate federal, state, and local regulatory bodies and must meet any 
applicable state or local notification requirements. 
6.2 Requirements and Qualificatidns 
Depending on the state, operators may be required to hold three forms of proof of competency: 
a manufacturer s training certificate (or equivalent), a radiation safety license, and a state lead- 
based paint inspection certificate or license. 
Manufacturer’s Training 
In most states, operators must be trained by the manufacturer or receive equivalent training. 
Syracuse staff took a one-day free training course on the use of the XRF instrument offered by 
the manufacturer, Niton. The course met New York state requirements and covered radiation 
safety, XRF theory, worker exposure, as well as hands-on analysis of dust wipes soils and paint. 
Radiation Licensing and Safety Training 
The U.S. Nuclear Regulatory Commission (NRC) requires radiation safety training for licens¬ 
ing purposes. Radiation safety officer certification is necessary before NRC will grant a license 
to own, operate, transfer, or store an XRF unit. Since Syracuse did not already have a radiation 
safety officer involved, staff first had to undergo a rigorous training program required by the 
state of New York to handle radioactive equipment. Once personnel were trained, Syracuse was 
XRF Use Licenses and Certification 
I n addition to training and any required accreditation, a person must have valid licenses or permits 
from the appropriate federal, state, and local regulatory bodies to operate XRF instruments. All 
portable XRF instrument operators should be trained by the instrument s manufacturer (or equivalent). 
Depending on the state, operators may be required to hold three forms of proof of competency: a manu¬ 
facturer s training certificate (or equivalent), a radiation safety license, and a state lead-based paint inspec¬ 
tion certificate or license. To help ensure competency and safety, EPA and HUD recommend hiring only 
operators who hold all three. 
The regulatory body responsible for oversight of the radioactive materials contained in portable XRF 
instruments depends on the type of material being handled. Some radioactive materials are federally reg¬ 
ulated by the U.S. Nuclear Regulatory Commission (NRC); others are regulated at the state level. States 
are generally categorized as agreement and non-agreement states. An agreement state has an agree¬ 
ment with NRC to regulate radioactive materials that are generally used for medical or industrial applica¬ 
tions. (Most radioactive materials found in XRF instruments are regulated by agreement states). For 
non-agreement states, NRC retains this regulatory responsibility directly. At a minimum, however, most 
state agencies require prior notification that a specific XRF instrument is to be used within the state. Fees 
and other details regarding the use of portable XRF instruments vary from state to state. Contractors 
who provide inspection services must hold current licenses or permits for handling XRF instruments, 
and must meet any applicable state or local laws or notification requirements. 
As an NRC-agreement state, New York regulates the handling of radioactive materials and the Syracuse 
Project is in compliance with all relevant state regulations. 
Analyzing Lead Dust Samples Using XRF Technology 
4 3 
