[ RadSafe ] RadSafe Digest, Vol 367, Issue 1

Thu Jul 29 11:46:36 CDT 2010

Dear Mike, Jack, Clayton, and Group:

You have a "Bully Pulpit" here. Perhaps you should collectively write a
position paper to clarify to various public officials the issues that can
result from a failed policy involving loss of inspectors...

Dan ii

--
Dan W McCarn, Geologist
108 Sherwood Blvd
Los Alamos, NM 87544-3425
+1-505-672-2014 (Home - New Mexico)
+1-505-670-8123 (Mobile - New Mexico)
HotGreenChile at gmail.com (Private email) HotGreenChile at gmail dot com

-----Original Message-----
From: radsafe-bounces at health.phys.iit.edu
[mailto:radsafe-bounces at health.phys.iit.edu] On Behalf Of Brennan, Mike
(DOH)
Sent: Thursday, July 29, 2010 10:19
To: radsafe at health.phys.iit.edu
Subject: Re: [ RadSafe ] RadSafe Digest, Vol 367, Issue 1

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 Bradt
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 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

> 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
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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