[ RadSafe ] ALARA

Brennan, Mike (DOH) Mike.Brennan at DOH.WA.GOV
Mon Jun 23 17:30:00 CDT 2008


The flexibility comes from knowledgeable people understanding what is
"reasonable" in a given situation.  As the situation changes,
particularly in an emergency, then what is reasonable changes.  
 
It also works the other way round.  For example, digital x-rays, as a
rule, involve more dose to the patient than do procedures using film.
But the information gained from digital x-rays is so much better that an
application of ALARA clearly shows that the increased dose is
reasonable, as the net result is a decrease in overall risk.  If the
regulation was written with a hard total dose number, it might well be
difficult, and certainly would take longer, to move to the better new
technology.  
 
I always liked a phrase that was on the front of some operating
instructions I one used:  "Nothing in these instructions should be
construed as precluding the use of good judgment."  Sadly, few
legislative or regulatory bodies will grant such freedom outright.  I
will settle for ALARA.

________________________________

From: garyi at trinityphysics.com [mailto:garyi at trinityphysics.com] 
Sent: Monday, June 23, 2008 3:02 PM
To: Brennan, Mike (DOH); radsafe at radlab.nl
Subject: RE: [ RadSafe ] ALARA


Hi Mike, 


I'm officially out of this topic, but I'm still interested so I'll
respond under an assumed name. I'm tempted to use Salsman but that's
already taken by someone using assumed names. How about Joe?  


OK, Mike, if what you say is true, then there would be less flexibility
if we got rid of Alara.  So how would that happen?  I just don't believe
that people who were previously capable of flexibility would suddenly,
without Alara, be rigidly constrained to following SOPs when faced by
emergencies.  


I'll concede that making up strategies to avoid trivial risks is a
creative exercise, and that Alara makes people get creative in order to
satisfy the Alara requirement.  Taking away Alara as a regulatory
requirement would probably reduce that creativity - no more lead lined
underwear! 


No, in fact Alara makes us less flexible.  Alara is a constraint, a
burden. 


-Joe, who is not Gary 


> SOPs and regulations both rest on the assumption that a group of 
> people sitting in an office writing them up know more than the person 
> who is dealing with a particular situation.  This is often true, but 
> not always, and the times it is not true are often the most important 
> one.  Having well thought-out, well written regs and SOPs is 
> important, but they are not the whole solution 






On 23 Jun 2008 at 11:35, Brennan, Mike  (DOH) wrote: 


Subject:                      RE: [ RadSafe ] ALARA 
Date sent:                    Mon, 23 Jun 2008 11:35:27 -0700 
From:                          "Brennan, Mike  (DOH)"
<Mike.Brennan at DOH.WA.GOV> 
To:                              <radsafe at radlab.nl> 


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I believe that what we get from ALARA that we cannot get from just 
writing clear regs is flexibility.  My formative years were spent in 
the Navy's nuclear submarine community, both on subs and teaching at 
Officer Submarine School.  The submarine community had (and presumably 
has) very well developed Standard Operating Procedures, designed to 
cover every foreseeable, or at least foreseen, possibility.  The crews 
are taught the SOPs, and use them to the point where many are 
memorized.  But additionally there is a program of training and 
testing of individuals so that they not only understand the SOPs, but 
the reasons behind them, and the assumptions that go into them, and 
the underlying principles that go into those assumptions.  This is the 
process that leads to someone becoming "Qualified in Submarines", and 
it is a non-trivial achievement to earn your dolphins.  The point of 
the qualification process it to produce people who can use the SOPs, 
but who also can recognize when the SOPs aren't moving the situation 
in the direction it should go, and creativity backed by deep knowledge 
is called for.  I can think of several dozen cases in which the crew 
had to leave the SOPs in order to save the ship or prevent highly 
undesirable consequences.  I was the person in charge in one such 
case.  


SOPs and regulations both rest on the assumption that a group of 
people sitting in an office writing them up know more than the person 
who is dealing with a particular situation.  This is often true, but 
not always, and the times it is not true are often the most important 
one.  Having well thought-out, well written regs and SOPs is 
important, but they are not the whole solution. 


-----Original Message----- 
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On 
Behalf Of garyi at trinityphysics.com Sent: Monday, June 23, 2008 10:45 
AM To: radsafe at radlab.nl; WILLIAM LIPTON Subject: Re: [ RadSafe ] 
ALARA 


Bill, 


Did Alara produce the successful facility, or did the successful 
facility produce doses that were Alara? 


In other words, if you went into a "dirty" plant and made them 
implement Alara, would the plant become a model facility?  Or would it 
still be "dirty" wherever scrutiny was lacking?  I agree that the 
correlation you recall exists, but I strongly doubt that Alara is the 
causative factor. 


Unless you are willing to insist that Alara is a causative factor, 
your concluding statement is unfounded.  I assert that the well run 
facilities you recall would have been just as well run (perhaps 
better) if Alara had never been conceived, had never been made a part 
of the compliance requirement. 


So I'm back to this:  Do we get anything from ALARA that we could not 
have just by writing clear regs?  


And, this is the last I will post on this issue.  I am so busy keeping 
things Alara that I have no more time to think about whether this is a 
good policy.  :P 


-Gary Isenhower 


- 
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