[ RadSafe ] Over-regulation: Does OSHA still reject use of Effective Dose Equivalent?

[howard long]

Coumadin (warfarin sodium, anti-clotting rat poison) is taken by millions of Americans in such precise and individualized dose that half again as much would cause dangerous bleeding. On the other hand, half the dose would cause significant risk of clot and stroke, the reason a doctor prescribes and monitors with clotting time the rat poison dose more carefully than perhaps any other medicine. Diabetics monitor their own, ever-changing insulin dose  Government regulators rarely hassle doctors or patients about these.
   
  What contrast to the minimal risks but mighty radiation regulation of governments !  
Is it time that HPs confront the self-serving bullies?
   
  Howard Long
  
Sandy Perle <sandyfl at cox.net> wrote:
  The following is a letter from a 1999 OSHA determination that 
rejected the use of Effective Dose Equivalent dose calculation and 
reporting. I am inquiring whether or not this position has ever been 
revised. I find no evidence that it has. If it has not, it appears to 
be an interesting position for OSHA to continue to pursue, 
considering that the various methodologies have been routinely 
accepted by state and other federal agencies (even the NRC now 
accepts the methodology when a individual who works with RAM also is 
exposed from radiologic procedures where a protective apron is worn). 
NCRP 122 provides significant details on all of the methodologies.

Any information will be appreciated.

Thanks,

Sandy

--------------------
REFERENCE POSITION

August 4, 1999

Charles H. Rose (MA,MSPH,D(ABSNM))
Executive Director
American Association for Nuclear Cardiology, Inc.
5660 Airport Boulevard
Suite 101
Boulder Colorado 80301

Dear Mr. Rose:

This is in response to your January 19, 1999 letter regarding the 
measurement of employee exposures to ionizing radiation. We apologize 
for the delay in our reply.

You report that some organizations have proposed and implemented a 
new method of monitoring the occupational radiation exposure of 
individuals who wear a protective apron. You state that these 
individuals may be monitored, for example, as follows:

One monitoring device is worn under the protective apron and a second 
one is worn outside the protective apron at the neck. An effective 
dose equivalent for external radiation is determined by multiplying 
the reading of the device located at the waist under the protective 
apron by 1.5 and adding this value to 0.04 of the reading of the 
device located at the neck.

You state that, "The American Association for Nuclear Cardiology 
(AANC) strongly opposes this "new" method of calculating occupational 
exposure." The AANC requests that the Occupational Safety and Health 
Administration (OSHA) state its position on this issue.

The "new" method of determining occupational exposure to external 
radiation does not conform with OSHA's standard for ionizing 
radiation, 29 CFR 1910.1096. As indicated by Table G-18 within 29 CFR 
1910.1096(b)(1), OSHA considers the components of the whole body to 
be the head and trunk, the active blood-forming organs, the lenses of 
the eyes, and the gonads. The head and trunk includes the neck, thus 
the neck is part of the whole body. According to 29 CFR 
1910.1096(a)(5), a dose to the whole body is the quantity of ionizing 
radiation absorbed, per unit mass, by any portion of the whole body. 
Therefore, the actual reading of the monitoring device that is 
positioned at the individual's neck indicates the whole body dose 
received by the individual. In point of fact, the whole body dose 
must be reported as the highest dose received by any region of the 
whole body.

Thank you for your interest in occupational safety and health. We 
hope you find this information helpful. Please be aware that OSHA's 
enforcement guidance is subject to periodic review and clarification, 
amplification, or correction. Subsequent rulemaking could also affect 
such guidance. In the future, should you wish to verify that the 
guidance provided herein remains current, you may consult OSHA's 
website at http://www.osha.gov. If you have any further questions, 
please feel free to contact OSHA's Office of Health Compliance 
Assistance at (202) 693-2190.

Sincerely,

Richard E. Fairfax, Director
Directorate of Compliance Programs
-------------------


----------------------------------------------------------------
Sandy Perle 
Senior Vice President, Technical Operations 
Global Dosimetry Solutions, Inc. 
2652 McGaw Avenue
Irvine, CA 92614

Tel: (949) 296-2306 / (888) 437-1714 Extension 2306 
Fax:(949) 296-1144

Global Dosimetry Website: http://www.dosimetry.com/ 
Personal Website: http://sandy-travels.com/ 

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