[ RadSafe ] RE: The State of Radiation Safety in the Industrial setting

Mon Sep 14 17:27:36 CDT 2009

Walt,

It was great talking to you this afternoon. 

I would have to say for the most part you're right on target with what I've found to be the case after talking to a good majority of the states.

I would say that we as an industry have two choices, 1) We step up as a group and correct ourselves, which we both know isn't likely as there will always be someone out there trying to undercut someone else, or 2) the regulators hammer on us levying fines like they were going out of style making us correct our problems.

I think the problems are being fixed here and there by some, but in other cases it's business as usual.

It’s a vicious cycle, we don't want the regulators looking over our shoulders, because we fear the fines. We don't talk to the regulators, because we fear the fines. And yet IF the regulators and we could build a good relationship, one where we could converse freely without fear of being fined for every t not crossed........ As I said a vicious circle. One that until the licensee WANTS to build and maintain a GOOD program will never get any better.

I have the fortune of working for a company with a solid program. Its disturbing for me to learn that we're a very small minority.

-----Original Message-----
From: Walt Cofer [mailto:radcontrol at embarqmail.com] 
Sent: Monday, September 14, 2009 12:13 PM
To: Scott Cargill
Cc: radsafe at radlab.nl
Subject: The State of Radiation Safety in the Industrial setting

Sorry Scott, but I beg to differ. In my opinion, the state of radiation safety in industrial radiography is far from great.  The industry is grossly under-regulated - not from a regulations perspective (those are quite extensive), but from an oversight perspective.  While part of the problem is that regulators are inadequately trained, the main issue is that the regulators are simply not conducting sufficient unannounced field inspections to ensure compliance.  This lack of oversight results in routine noncompliance and unnecessary exposures to personnel.  Radiographers know that the odds of an unannounced field inspection are slim to none, so they know that they can get away with lax adherence to safety procedures.  Its the equivalent of roads with no speed limit enforcement; drivers will speed when they know they are unlikely to be caught.

The NRC and Agreement States talk a lot about risk-based regulations and enforcement, but they don't walk the walk, because if they did, they would be devoting a great deal more resources to ind. radiography field inspections; instead their focus has been on increased security controls, which do very little to improve worker safety.

As a former radiographer, former state regulator, and as a practicing consultant with multiple radiography clients, trust me when I tell you that many radiographers continue to be inadequately trained and inadequately supervised, both internally and externally, and that unsafe conditions continue to exist.  I'll admit that the situation is much better in the U.S., Canada and Europe, where there is better equipment, better management, and better oversight (and more lawyers - also a factor), so we tend to see the worst accidents occurring in other countries, but no one should be deluded into believing that improved equipment and stricter rules has solved the industry's problems.  Just because the frequency of source disconnects is down doesn't mean that accidents aren't continuing on a regular basis.  If you doubt me, I suggest that you visit the NRC's Event Reports site and see how many reportable events are radiography-related - and those are just the ones the regulators find out about; don't think that there aren't plenty more that go unreported.

If it sounds like I'm blaming the regulators, then my message is clear.  Lax regulatory oversight is rewarding the companies that cut corners on safety while punishing the companies that invest in safety; the bad actors gain an economic advantage that can only be curtailed while the playing field is leveled, and that will only happen when the NRC and states make it happen.

And don't get me started on the failure of third party radiographer certification to make a difference; simply put, it hasn't; because the enforcement component is, if not a complete failure, close to it.

Sorry to be such a pessimist, but I call it as I see it. 

Walt Cofer
Radiation Control, Inc.
Tallahassee, FL
Tel:    (850) 668-8559
Cell:   (850) 519-5351
Email: radcontrol at embarqmail.com

----- Original Message -----
From: Scott Cargill <scott at vxray.com>
To: radsafe at radlab.nl
Sent: Wed, 9 Sep 2009 16:29:13 -0400 (EDT)
Subject: [ RadSafe ] The State of Radiation Safety in the Industrial setting

I'm working on a paper to be presented at ASNT's (American Society of
Non-Destructive Testing)  fall conference (Oct 2009) 

I thought I would explore the question of "What is the State of
Radiation Safety" specifically in the U.S. the real question I have is
how are we doing from the Rad Safety view, I would think it could be
said that compared to the 1980s we're doing great, no source disconnects
on a daily basis, very few personnel over exposures, etc. But then again
that would be an assumption on my part. So my question to you all is
what do you think?

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