[ RadSafe ] ALARA

Mon Jun 23 18:43:08 CDT 2008

Mike, isn't it obvious that the flexibility you have is the choice of how you will comply?  And 
isn't it obvious that there is no net value in that?  Sure, you have the flexibility of how to 
comply,  ***but you have the added regulatory burden***.  That's not something I would go 
out of my way to obtain.

Put it like this.  What if I could regulate a tax increase for you of up to  1000%, BUT I phrase 
it so that you only have to pay As Much As Reasonably Achievable.  Further, I make it so you 
can pay by check, cash, money order, credit card, gold bullion, or on a convienient monthly 
payment plan.  You will need a trained expert to help you determine your AMARA payment, 
but think of all the good your tax money will do.  

BTW, AMARA only applies to radiation protection professionals.  All other industries and 
individuals will continue at the same tax rate.

With all that flexibility, and the knowlegeable people understanding what is "reasonable" for 
you, you should be very happy with that, right?  I mean, that plan is LOADED with flexibility.

On a side note, someone in authority here in Texas has decided that a hard total dose 
number IS "reasonable" for digital x-rays.  You were probably  right when you said:

"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.  "  

Violations for the exceeding the patient entrance doses can be quite hefty.  The regulatory 
agency here is doing much better since they began supporting themselves thru this 
previously untapped revenue stream.  Viva ALARA!

Have a nice day,
-Gary Isenhower

On 23 Jun 2008 at 15:30, Brennan, Mike  (DOH) wrote:

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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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