[ RadSafe ] Source control, etc.

[Earley, Jack N]

Some years ago, I developed and presented source control training for a power plant in New York state. After several complaints from trainees who had failed their first written exam, their director came to look at the exam bank; I offered to remove any questions that she felt they didn't need to be tested on. She didn't remove any questions, but she did write two violations against herself for not being aware of and implementing some of the requirements.

When I took over as RSO at a company in Texas a couple of years later, the first thing I did was to develop a checklist of state regulations, and then used it to verify compliance, starting with a source inventory; several sources were missing. Next on the list were radiological surveys. None of the supposed monthly surveys were even close to actual; there was a Radiation Area in the parking lot when instrument calibrations were being performed.

I recently developed a 150-item compliance checklist for Environmental Compliance Officers. Even at that, it was rather broad, encompassing a significant number of responsibilities within each identified item. But the idea was to ensure that they were aware of all that they're responsible for so they can self-identify any deficiencies and schedule them for correction. It's always better to find opportunities for improvement internally than externally.

Trust, but verify. That's what I believe is the role of state and federal regulators. It's my job to ensure that my program is compliant, not theirs. When I was in charge of the environmental quality assurance program, I always scheduled an independent assessment right behind the management assessment, partly to ensure that the management assessment process was effective. And I also recommended to the program managers that they assess the weakest aspects of their programs first (however they chose to define that). 

So although I understand Clayton's position, it really shouldn't matter whether the state assesses a program quarterly, annually, or triennially; it should relate to the significance of the program. But it seems to me that the programs should be self-supporting, i.e., supported by service fees and fines for non-compliance, which would then allow them to focus on the aspects of their programs that they consider weakest/most significant for protecting workers, the public, and the environment. If it isn't feasible for them to be self-supporting, then they have the option of reducing their inspection frequencies while increasing their focus in those areas that are most significant. At some point, a licensee has to decide that it's either more cost-effective to be compliant, or that they should be in a different line of work.


Jack Earley
Sr. Health Physicist

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> Message: 1
> Date: Mon, 26 Jul 2010 14:06:10 -0400
> From: Clayton J Bradt <CJB01 at health.state.ny.us>
> Subject: [ RadSafe ] Lost sources at Illinois Hospital