[ RadSafe ] RadSafe Digest, Vol 367, Issue 1

Brennan, Mike (DOH) Mike.Brennan at DOH.WA.GOV
Thu Jul 29 11:19:01 CDT 2010

Hi, Clayton.

"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."

This strikes me as a very bad idea (this is not a criticism aimed at you
Clayton, as I assume you didn't create this policy).  

I don't know how the contractors are chosen, or how it is determined
which contractor inspects which facility, or how the licensees are made
to correct discrepancies, but the best system I can see coming out of
this is much like a state program, but with more cumbersome
communications and less efficient billing.  Even if all players are
completely honest, I see the potential for arguments between contractors
as to who gets to do the most profitable licensees, and difficulty for
licensees in inconvenient places to get an inspector to come to them.
And, of course, any system where an individual regulator is taking money
directly from the regulated is a system begging for corruption to occur
(when the traffic cop collects the fine on the spot, and gets to keep
what he collects, the number of traffic stops will likely go up, but the
quality will certainly go down.)


-----Original Message-----
From: radsafe-bounces at health.phys.iit.edu
[mailto:radsafe-bounces at health.phys.iit.edu] On Behalf Of Clayton J
Sent: Wednesday, July 28, 2010 12:13 PM
To: radsafe at health.phys.iit.edu
Cc: Jack_N_Earley at RL.gov
Subject: Re: [ RadSafe ] 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
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
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
state contracts out to private firms to do the work.  In many NY
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
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
up on the licensees?

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


> Date: Tue, 27 Jul 2010 10:53:30 -0700
> From: "Earley, Jack N" <Jack_N_Earley at RL.gov>
> Subject: [ RadSafe ] Source control, etc.
> To: "radsafe at agni.phys.iit.edu" <radsafe at agni.phys.iit.edu>
> Message-ID:
>    <F4561CBF4FBBF240BEF1370289612DDAD281BDDE1A at EMDB01-1.rl.gov>
> Content-Type: text/plain; charset="us-ascii"
> 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
> 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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