[ RadSafe ] Source control etc.

[Earley, Jack N]

I used two different words to convey the relative responsibilities of licensees and regulators. Licensees are responsible to ensure (synonyms "make certain," "guarantee") that their programs are 100 percent compliant. Regulators verify (synonyms "confirm," "validate," "corroborate").

I listed the details of some of the processes I use to ensure compliance, but I wouldn't expect a regulator to do more than a statistical sample of a program to validate it periodically. Not to mention that there are various methods of performing assessments, including desktop assessments of documentation. In some cases, these may be adequate; in others, they're a precursor to a site visit.

As I said, I understand your position, but I see it as a matter of perspective.

As a footnote, a friend of mine had his budget cut at the hospital where he works, because his department was an expense item, i.e., overhead. So he decided to make it a profit center instead. Now they can take his profits, but at least they can't reduce his staff due to budget shortages unless they want to kill the goose that lays the egg (always an option, of course).


Jack Earley
Sr. Health Physicist

Don't Say It - WRITE IT!
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From: Clayton J Bradt [mailto:CJB01 at health.state.ny.us]
Sent: Wednesday, July 28, 2010 12:13 PM
To: radsafe at agni.phys.iit.edu
Cc: Earley, Jack N
Subject: Re: RadSafe Digest, Vol 367, Issue 1


Jack Early wrote:

"Trust, but verify."

Exactly! But the only way to verify is to physically be there.

With regard to state radiation programs being self-supporting: I don't know how it may work in other states, but here in NY the early retirement incentives being used currently to reduce the workforce come with the proviso that the positions can't be refilled. Similarly, the threatened future layoffs will also be non-refillable. The point after all is to reduce the state workforce, not just replace current workers with new ones. So regardless of how much money a program collects in fees, if it can't hire people to do the work, the work won't get done. Unless of course the state contracts out to private firms to do the work. In many NY agencies this is a common practice. Indeed, even within the radiation control program certain classes of x-ray installations (e.g. dental x-ray) are inspected primarily by private contractors who collect a fee directly from the registrant. Perhaps this practice will be expanded to cover some materials licenses as well.

The problem of verification would still remain, however, for who would check up on the contractors to ensure they are doing their job of checking up on the licensees?

Clayton J. Bradt
Principal Radiophysicist
NYS Dept. of Health
Biggs Laboratory, Room D486A
Empire State Plaza
Albany, NY 12201-0509

518-474-1993