Of all the nondestructive testing (NDT) methods, industrial radiography with sealed sources carries the heaviest record-keeping load, because the paperwork is not about the quality of the inspection but about the safety of the people doing it and everyone nearby. A radiography licensee answers to its radioactive materials license and to the regulations behind it, and an inspector checks both by reading records.
This guide sets out the records 10 CFR Part 34 requires of an NRC licensee — radiographer training and certification, the radiation safety officer's field audits, personnel monitoring, leak tests, inventories, equipment checks and utilization logs — with the intervals and retention periods, and where to find each rule.
Who may act as a radiographer
Section 34.43 sets the gate. Before anyone acts as a radiographer, the licensee must be able to show that the person:
- has been trained in the subjects listed in 34.43(g) — radiation safety fundamentals, detection instruments, the equipment, the regulations and case histories of radiography accidents;
- has at least two months of on-the-job training;
- is certified through a radiographer certification program run by a certifying entity meeting Appendix A of Part 34;
- has received copies of, and instruction in, the regulations, the license and the licensee's operating and emergency procedures, and passed a written or oral exam on them; and
- has been trained on the licensee's own exposure devices, sources, daily inspections and survey instruments, and passed a practical exam on them.
A radiographer's assistant needs the instruction, a written test, competence developed under a radiographer's personal supervision, and a practical exam. Under Appendix A, a certifying entity's certification period must be between three and five years, so the radiographer certification itself has an expiry to watch.
Radiographer certification is a radiation safety credential. It is separate from, and does not replace, the NDT method certification the same person holds under a written practice; a radiographer usually carries both, on different clocks.
Refresher training and field audits
Two recurring obligations follow initial qualification. Annual refresher safety training is required for every radiographer and radiographer's assistant at intervals not to exceed 12 months (34.43(d)).
The second is the inspection of job performance, which everyone calls the field audit. Under 34.43(e), the RSO or a designee runs a program that observes each radiographer and assistant during an actual industrial radiographic operation, at intervals not to exceed six months. A mock-up in the shop does not count. If a person has not taken part in a radiographic operation for more than six months since their last inspection, they must re-demonstrate their knowledge by a practical examination before they next take part. The program is not required where one individual is both the radiographer and the RSO and performs all the radiography.
Section 34.79 says what the record must show: topics, dates, instructors and attendees for refresher training, and for each field audit a list of the items checked and any non-compliances the RSO observed. A signature and a date on a blank form is not an audit record.
The radiation safety officer
Section 34.42 sets minimum qualifications for an industrial radiography RSO: the training and testing in 34.43(a), 2,000 hours of hands-on experience as a qualified radiographer, and formal training in establishing and maintaining a radiation protection program. The duties it lists include overseeing the training program, ensuring surveys and leak tests are done and documented, ensuring personnel monitoring devices are calibrated and used properly and their results recorded, and stopping operations when necessary. Most of the records in this guide are, in the regulation's words, the RSO's to ensure.
Personnel monitoring
Section 34.47 requires every radiographer and assistant, at all times during radiographic operations, to wear a direct reading dosimeter, an operating alarm ratemeter and a personnel dosimeter. The alarm ratemeter can be dropped at a permanent installation that has other alarming or warning devices in routine use. The records that follow from it:
- Direct reading dosimeters are read, and the exposure recorded, at the beginning and end of each shift.
- Pocket dosimeters are recharged at the start of each shift, and pocket or electronic dosimeters are checked for correct response at least every 12 months.
- Film badges are replaced at least monthly, other personnel dosimeters needing replacement at least quarterly, and all are evaluated at least quarterly or promptly after replacement.
- Alarm ratemeters are checked to sound before use at the start of each shift, and calibrated at least every 12 months.
- If a pocket dosimeter is off scale, or an electronic dosimeter reads above 2 mSv (200 mrem), and radiation exposure cannot be ruled out, the personnel dosimeter goes for processing within 24 hours and the person stops work with licensed material until the RSO or designee has determined their dose. A lost or damaged personnel dosimeter stops work too, until it is replaced and the exposure calculated.
Personnel dosimeter results, and the estimates made after an off-scale or lost dosimeter, are kept until the NRC terminates the license (34.83). Those are the records that outlive everyone who made them.
Sources, devices and instruments
Leak tests. Each sealed source is tested for leakage at intervals not to exceed six months (34.27(c)), by an approved method, with the wipe analyzed by a person specifically authorized to do it and able to detect 185 Bq (0.005 µCi). A source in storage and not in use need not be tested until it is used or transferred, but must be tested first if it has been stored more than six months. A result at or above that threshold means the source is treated as leaking: the equipment comes out of use and a report is due within five days. Exposure devices with depleted uranium shielding and an S-tube are tested for DU contamination at intervals not to exceed 12 months.
Quarterly inventory. A physical inventory of every sealed source and every device containing depleted uranium, each quarter (34.29). The record carries the date, who did it, and for each source or device the radionuclide, activity, location, manufacturer, model and serial number (34.69).
Survey meters. Calibrated at intervals not to exceed six months and after servicing other than a battery change (34.25).
Daily checks and quarterly maintenance. Survey meters, exposure devices, containers, associated equipment and source changers get visual and operability checks before use each day they are used, and inspection and routine maintenance under written procedures at intervals not to exceed three months (34.31). Equipment problems and maintenance are recorded with the date, inspector, equipment, problem found and repair done (34.73).
Utilization logs. For each sealed source: the device or container it is in, the radiographer it was assigned to (identity and signature), the site, and the dates it was removed from and returned to storage (34.71).
Intervals and retention at a glance
| Record | Interval | Keep for | Section |
|---|---|---|---|
| Radiographer training and certification | Before acting as radiographer | 3 years | 34.43, 34.79 |
| Annual refresher safety training | Not over 12 months | 3 years | 34.43(d), 34.79 |
| Field audit (inspection of job performance) | Not over 6 months | 3 years | 34.43(e), 34.79 |
| Direct reading dosimeter readings | Start and end of each shift | 3 years | 34.47(b), 34.83 |
| Dosimeter response and alarm ratemeter calibration | Not over 12 months | 3 years | 34.47, 34.83 |
| Personnel dosimeter results and dose estimates | Evaluated at least quarterly | Until the license is terminated | 34.47, 34.83 |
| Sealed-source leak test | Not over 6 months | 3 years, or until a stored source is removed | 34.27, 34.67 |
| Quarterly inventory | Quarterly | 3 years | 34.29, 34.69 |
| Survey meter calibration | Not over 6 months | 3 years | 34.25, 34.65 |
| Equipment problems and maintenance | Daily checks; maintenance not over 3 months | 3 years | 34.31, 34.73 |
| Utilization log | Each use | 3 years | 34.71 |
Our own layout of the eCFR text current in September 2026. Agreement State rules and license conditions may differ; check yours.
Where the records have to be
Section 34.89 requires the full set at the location the license names, and a working subset at each field station and temporary jobsite: the license, the regulations, the utilization records for devices dispatched from there, daily check records, direct reading dosimeter readings, the operating and emergency procedures, the latest survey meter calibration, the latest alarm ratemeter calibration and dosimeter checks, the latest survey records and the shipping papers. On a pipeline spread or at a refinery turnaround, that means the records have to travel with the truck or be reachable from it.
Section 34.87 lets records be kept electronically, provided they stay legible, accurate and complete for the whole retention period and are safeguarded against tampering and loss. As amended in December 2025, that section carries a sunset date of 8 January 2027 unless the NRC extends it, so check its current status before relying on it.
Reportable events
Section 34.101 requires a written report to the NRC within 30 days of an unintentional disconnection of the source assembly from the control cable, an inability to retract the source to its fully shielded position and secure it, or the failure of a component critical to safe operation. Other reporting duties, including overexposures, sit in other parts of the regulations and in your license. Whether an event is reportable, and by when, is the licensee's call.
Radiography crews also carry the method certifications and vision exams every NDT technician needs, and on nuclear work the qualification rules in the nuclear qualification guide on top. The certification tracking guide covers keeping those clocks together.
For the arithmetic around a shot, such as a source's activity today, where the 2 mR/h and 100 mR/h lines fall, or how much a shield cuts, the free NDT calculators show each formula and the regulation or reference it comes from.
How TRACE handles it
The Safety module keeps these records. Radiation safety refreshers and other trainings carry their expiry dates. Dose reports are transcribed or imported per technician, with each year's total set against the 10 CFR 20 annual limits and any ALARA investigation levels you enter, and a printable annual record. Each field audit records who observed, what they saw, the result and the corrective action; each radiographer's next audit comes due six months after the last, and anyone logged as a radiographer in the past year with no audit on record is listed.
Sealed sources carry a six-month leak-test schedule. The source log records each check-out and return, with optional pocket dosimeter readings and survey meter checks, and radiographers can keep it from TRACE Mobile. Quarterly inventories, instrument calibrations, device maintenance and license expiries come due on the calendar and in the digest; area surveys and shipments are recorded beside them, and a reportable event reminds you of the notify-by and report dates you set. Your own program can set field audits and inventories more often than the rule, never less. With the People module, vision exams sit on the same technician.
TRACE is record-keeping. It is not a substitute for your radiation safety program, and the RSO named on your license keeps every responsibility that license assigns.
Frequently asked questions
How often must sealed sources be leak tested?
Under 10 CFR 34.27(c), at intervals not to exceed six months, by a method approved by the NRC or an Agreement State, with the analysis done by a person specifically authorized to do it. A source in storage and not in use need not be tested, but must be tested before use or transfer if it has been stored for more than six months. Leak test records are kept for three years, or until a source in storage is removed (34.67).
How often does the RSO have to audit a radiographer in the field?
10 CFR 34.43(e) requires the RSO or a designee to observe each radiographer and radiographer's assistant during an actual industrial radiographic operation at intervals not to exceed six months. Someone who has not taken part in a radiographic operation for more than six months since their last inspection must pass a practical examination before they next take part. The inspection program is not required where one person is both the radiographer and the RSO and performs all the radiography.
How long are dosimetry records kept?
Under 10 CFR 34.83, personnel dosimeter results, and estimates of dose after an off-scale direct reading dosimeter or a lost or damaged personnel dosimeter, are kept until the NRC terminates the license. Direct reading dosimeter readings, their yearly operability checks and alarm ratemeter calibrations are kept for three years.
Does this apply in an Agreement State?
In an Agreement State the state's radiation control program licenses industrial radiography under its own regulations, which are generally built to be compatible with the NRC's. The requirements are usually close to Part 34 but the section numbers, and sometimes the details, differ. Work from your own license and your state's rules.
Checked against
- 10 CFR Part 34, Licenses for Industrial Radiography and Radiation Safety Requirements for Industrial Radiographic Operations (eCFR, text current at 1 September 2026), sections 34.25, 34.27, 34.29, 34.31, 34.41, 34.42, 34.43, 34.47, 34.65–34.73, 34.79, 34.83, 34.85, 34.87, 34.89, 34.101 and Appendix A
- Agreement State regulations were not reviewed; they are described in general terms only
This guide summarises the documents above in our own words to help you find your way around them. It is not a substitute for them: requirements change between editions and contracts add their own, so check every figure against your own licensed copy and your written practice before you rely on it.
Named for reference only. TRACE is an independent product: it is not affiliated with, endorsed by, sponsored by or accredited by the U.S. Nuclear Regulatory Commission (NRC), or by any other organization whose standards or programs it describes. Their names and marks are their own.