A Q&A with RSCS Health Physics Professional, Witold Tatkowski NRRPT, CSP
Radiation protection programs aren’t just binders on a shelf, they’re living systems designed to protect workers, the public, environment, and your organization. While radiation regulations vary by state, most state programs are based on, or closely aligned with, requirements established by the U.S. Nuclear Regulatory Commission (NRC).
Across jurisdictions, licensees and registrants are required to develop, document, implement, and periodically review their radiation protection programs. We sat down with RSCS Health Physics professional, Witold Tatkowski, to walk through why radiation protection program audits are required, how they’re typically performed, and what organizations should be looking for in an effective review.
Q: What is a radiation protection program audit, really?
A radiation protection program audit is a structured evaluation of how an organization manages radiation safety—both on paper and in practice.
Regardless of the state you operate in, regulations generally require licensees to maintain a program that ensures compliance and keeps radiation doses As Low As Reasonably Achievable (ALARA). The audit verifies licensing commitments, written policies, procedures, and controls that are actually being implemented effectively in day-to-day operations.
It goes beyond documentation and focuses on how the program functions in practice.
Q: Why are annual program reviews required?
NRC and State regulations, mandate that radiation protection programs be reviewed at least annually.
For NRC-regulated licensees, this requirement is clearly stated in 10 CFR 20.1101, which requires licensees to:
- Develop and implement a radiation protection program appropriate to their activities
- Use procedures and engineering controls to maintain ALARA
- Periodically (at least annually) review program content and implementation
The reason is simple: operations evolve. Staffing changes, equipment changes, and workloads shift. Annual reviews ensure your program still reflects reality and that gaps are identified before regulators do.
Q: What does RSCS review during a radiation protection audit?
We review both program documents and program implementation, which is exactly what NRC-based regulations require.
That includes:
- Licensing documents
- Radiation protection policies and procedures
- ALARA program structure and effectiveness
- Training and qualifications of personnel
- Dosimetry and dose trending
- Radiation surveys and monitoring practices
- Instrumentation use and calibration
- Event response, corrective actions, and records
We’re not just asking whether documents exist. We’re assessing whether controls are appropriate, effective, and consistently applied.
Q: How is an RSCS audit different from a basic compliance review?
Some audits focus on minimum compliance: Is there a procedure? Is there a record?
RSCS takes a broader, risk-informed approach. We ask:
- Does the program align with actual operations?
- Are controls proportional to the hazard?
- Is ALARA actively applied or just referenced?
- Would this program stand up to regulator scrutiny?
Because RSCS supports radiation programs across medical, research, educational, industrial, and nuclear environments, we understand how NRC-based regulations are interpreted and enforced in the real world and not just how they read on paper.
Q: Why is ALARA such a central focus of the audit?
ALARA is a foundational principle in NRC regulations and most state programs, but it’s often misunderstood.
We evaluate whether:
- Procedures are designed to reduce exposure
- Dose trends are reviewed and acted upon
- Management is engaged in radiation safety decision-making
A strong ALARA program demonstrates to regulators that radiation protection is proactive, intentional, and embedded in operations and not an afterthought.
Q: Who should be performing radiation protection program audits?
While regulations allows internal reviews, independence and expertise are critical.
An external audit:
- Brings an unbiased perspective
- Identifies gaps internal teams may miss
- Provides defensible documentation
- Strengthens inspection readiness
RSCS audits are conducted by experienced health physics professionals who understand both regulatory intent and operational realities.
Q: What do clients receive after an RSCS audit?
Clients receive a clear, structured audit report that:
- Documents compliance with NRC-based requirements
- Identifies findings and observations
- Prioritizes corrective actions
- Supports regulator inspections and license reviews
We also work collaboratively with clients to address findings. Whether that means refining procedures, improving training, or strengthening ALARA controls.
Q: How does RSCS approach radiation protection program audits?
Radiation protection is one of our core expertise.
RSCS combines:
- Deep knowledge of NRC and state regulations-based regulatory frameworks
- Hands-on operational experience
- Practical, defensible audit methodology
- A partnership-driven approach
Our audits don’t just help clients meet regulatory expectations, they help build programs that are effective, sustainable, and inspection-ready.
While radiation protection regulations vary by state, the expectation is universal: programs must be implemented, effective, and reviewed regularly.
RSCS helps organizations meet and exceed those expectations with audits that deliver clarity, confidence, and real operational value.
Contact RSCS for additional information about radiation protection program audits or visit our program and development assessment page for more details.