[ RadSafe ] RadSafe Digest, Vol 368, Issue 1

Earley, Jack N Jack_N_Earley at RL.gov
Thu Jul 29 12:45:24 CDT 2010

Mike Brennan wrote:

> "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.)

Another part of my job as RSO in Texas was to provide third-party certification of radiation-generating devices, to analyze leak-test smears, and to provide radiographer training. We were contacted by various parties who needed these services, just as I contacted other businesses who provided services that I needed. Why would I jeopardize my RSO certification, or my company's ability to provide these services, by falsifying records? In fact, I declined to certify several devices that my predecessor had certified because the owner or device was non-compliant with regulations (they were still billed for the inspection). I've also failed any number of trainees over the years for not meeting testing standards (and, yes, I've been offered bribes to do otherwise).

The IRS recently banned for life a mother-daughter team from preparing tax returns for others. The IRS examined 100 tax returns, of nearly 20,000 that the couple had prepared, and identified almost $1,000,000 in inflated deductions. The statistical sampling was sufficient for them to identify a weakness that they can now pursue in detail. I think that's the right approach (probably because that's also how I do independent assessments). And if state regulators can review the processes of third-party certifiers (or laboratory accreditations) to infer the compliance of a larger number of licensees, that seems highly efficient to me. Maybe states will start certifying assessors to perform that function as a way to cope with budget cuts; they already use professional engineer certifications for any number of other functions, such as for approving contingency plans.

Jack Earley
Sr. Health Physicist

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