Handling Tritium Exit Signs 

Tritium (³H) is a radioactive isotope of hydrogen and an active material that makes the exit signs glow in the dark without power. This low-energy beta particle can be stopped by paper, clothing and skin. Tritium exit signs are widely used by a surprisingly large number and type of facilities throughout the United States. Few facility owners are aware that the exit signs installed in their facilities are tritium exit signs. These common signs are regulated by the Nuclear Regulatory Commission (NRC) and the 36 Agreement States; therefore, the signs necessitate proper management and handling to ensure compliance with federal and state requirements.  

It is important to understand how to identify and properly handle a tritium exit sign to avoid damage and improper disposal. A tritium exit sign can be identified by the following characteristics:

• Sealed glass tubes coated with a phosphorescent powder and filled with tritium gas
• Colored, dark background with letters that:
• Appear clear or white, and unlit in lightened conditions
• Glows green in the dark
• No electrical connections or batteries

• Labeling on the side, edge or back of the sign that includes:
  - Magenta-and-yellow trefoil (radiation symbol) and “Caution: Radioactive Material”
  - Nuclear Regulatory Commission sticker
  - Manufacturer’s NRC license and contact information
  - 10-20 year life cycle

While owning a tritium exit sign is legal, facility owners must address the regulatory obligations that accompany ownership of this device. The NRC recently issued a package of challenging compliance responsibilities, including the following:

• Regulated by NRC and Agreement States – Tritium exit signs are regulated by the NRC under 10 CFR 31.5 and 32.51a and by the 36 Agreement States under the applicable state regulations. The basic requirements include the assignment of a responsible person within the end-user organization who will oversee the proper use and management of signs, including the proper disposal of inactive signs and notifications when signs are damaged, lost or transferred. In addition, the labeling and radiation symbol on the sign may not be removed or covered.
  Signs that are transferred to the manufacturer must be packaged and shipped per the Department of Transportation shipping regulations. In addition, limits on the amount of curies shipped per box and per day must be realized and cannot be breached during the transfer of tritium exit signs.
• Inventory and Reporting Requirements – Sign manufacturers provide the NRC and Agreement States a list of end-users. Users are required to notify the NRC or Agreement State when signs are damaged, broken, transferred, or lost. Many states are increasing their tracking systems – Colorado and Nebraska have annual inventory programs for users of tritium exit signs. A damaged tritium exit sign requires a response by a properly licensed contractor and notification to the NRC or Agreement State.
• High Civil Penalties – The NRC has indicated that its policy is to issue high civil penalties for improper disposal of tritium exit signs (for example: fines up to $5,000 per missing sign).
• Perceived Human Exposure – While potential radiation exposure is comparable to dental x-rays or transcontinental flights, a misinformed perception by workers or customers may create a potential for claims.
• Expensive Remediation – When the glass tubes of a sign are broken and the tritium is released, the sign must be removed from service and an expensive clean-up response is required due to the potential for radioactive contamination. The tritium released can expose nearby personnel or public to radiation and residual tritium contamination can pose an ongoing risk.
• Expensive Monitoring – Damaged tritium exit signs create the potential for, or perception of, exposure to radiation and radioactive material. Radiological assessment, including surveys or monitoring personnel and buildings, to minimize liabilities can be expensive.
• Operational Shut Downs – Because tritium is highly water soluble, the food processing and related industries are especially vulnerable. In one case, a food processor was forced to shut down a processing line for decontamination after a fork lift damaged a tritium exit sign. Termination of operations to perform remedial activities results in lost production and increased cost.
• Potential Superfund Liability – Tritium has been found in leachate from landfills in California, Pennsylvania, New Jersey and the province of Ontario. Regulators suspect that improperly disposed tritium exit signs may, in part, have been a source. This puts tritium exit sign owners at risk for future liabilities and remediation costs associated with cleaning up these legacy sites.

On January 16, 2009, the NRC released a “demand for information” to 62 organizations possessing 500 or more tritium exit signs. The demand required that the organizations provide an explanation of how it complies with the regulatory requirements applying to the possession, transfer and disposal of tritium exit signs. The demand also required the organizations to respond with the following information:

• Confirmation of the total number of signs possessed
• Reasons for any discrepancies and actions taken or planned to locate missing signs
• Actions taken or planned to prevent future losses

All responses were due by March 16, 2009, (within 60 days of request). The organizations receiving the demand for information were identified through the NRC’s General License Tracking System, which contains information filed by sign manufacturers. The organizations include large retail store chains, churches, federal and state agencies, school districts and universities. The NRC will likely identify a second tier of user organizations once the initial round of responses is received.

Retailers must be aware if they have signs, and must know how to properly manage signs at their stores and facilities. Best practices that retailers should follow include:

• Checking for tritium exit signs in their stores and facilities
• Developing a tritium exit sign management plan
• Designate a “person of authority” responsible for managing tritium exit signs
• Develop standard operating procedure for safe and proper handling
• Create an inventory of existing tritium exit signs
• Identify any critically damaged tritium exit signs (tubes missing or broken)
• Inform and train store employees and contractors on the proper handling of tritium exit signs