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Licensees who employ certified exposure device operators

The Nuclear Substances and Radiation Devices Regulations contain several requirements related to the possession and use of exposure devices, and licensees' obligations. Under the current certified exposure device operator (EDO) program, licensees are responsible for all licensed activities conducted by certified EDOs while in their employment.

As of January 1, 2017, the CNSC will consider a worker qualified to operate an exposure device only if they have a valid EDO certification card (that is, a card issued on or after February 1, 2013 that has not expired). As a result, any EDO whose certification card does not have an expiry date or whose certification card has expired will not be considered qualified to work as a certified EDO.

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Record keeping

Licensees are responsible for documenting EDO candidate and certified EDO training activities and keeping records of this training for 3 years after the termination of employment of the EDO/EDO Trainee. The record should include:

  • the full legal name of the EDO candidate/certified EDO
  • the number of training hours completed by date
  • training topic area(s) covered by date
  • Supervisor or Radiation Safety Officer (RSO) sign-off for each topic area

Licensees are also responsible for documenting and recording any activity completed during reinstatement training for certified EDOs who begin work following a significant interruption in their work history. These records will be included as additional documentation in support of EDO certification renewal.

Making attestations

All attestation forms and letters must be signed by authorized representatives of the licensee. An authorized representative is a RSO, alternate RSO, or representative listed in the annual compliance report who could reasonably have knowledge of the EDO candidate's knowledge and ability.

Authorized representatives can delegate other employees to act as authorized representatives for the purposes of EDO certification by notifying PCD EDO Team. The CNSC keeps a record of all employees with authorized representative delegation.

For EDO trainees

Licensees are responsible for attesting to the successful completion of the EDO candidate's on-the-job training (OJT) by signing OJT attestation forms.

For certified EDOs

Licensees are responsible for signing an employer attestation form to attest that the certified EDO applying for renewal is/was employed for the time period listed in the form AND that the certified EDO has the knowledge, skills and abilities to safely operate an exposure device.

Furthermore, if not provided as part of the activity, licensees are responsible for providing an attestation, letter or certificate of attendance for continuing training activities completed by certified EDOs in their employment.

Finally, licensees are responsible for providing an attestation, letter or certificate of attendance as documentation that a certified EDO completed reinstatement training to the licensee's satisfaction.

Providing training

For EDO trainees

Licensees are responsible for delivering OJT to EDO candidates that covers the topics outlined in appendix A section A2 of CSA PCP-09, Exposure Device Operator Personnel Certification Guide – Revision 1. Licensees are also responsible for ensuring that any employee appointed as a supervisor of the OJT holds a valid EDO certificate for the duration of the OJT.

For certified EDOs

In collaboration with the certified EDO, licensees are responsible for determining the scope of reinstatement training the certified EDO completed following a significant interruption in work.

The CNSC generally considers the following activities acceptable reinstatement training following a significant interruption of 12 or more months:

  • at least 320 hours of EDO duties performed under supervision
  • self- or employer-led study of:
    • CNSC regulations and requirements related to EDO certification, gamma radiography and radiation protection
    • licensee procedures
  • employer verification of reinstatement training, for example:
    • employer-developed testing
    • CNSC EDO practical examination

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