[ RadSafe ] Question for Legal Eagles + Associates

[dkjordan2001 at yahoo.com]

Good Day Mr. Alston,

It was my understanding that action levels were established by regulated entities to ensure they stayed well below regulatory limits. 

We dealt with a lot of companies that employed large, portable sealed sources.  Most of these were Special Form to avoid needing a Type B container to transport.  If one of these sources failed a leak test it was no longer Special Form and could not be moved without expensive re-packaging.  Several customers established action levels at a fraction of the leak test pass/fail limit so they could move theses sources to their final resting place before they failed the test.

Several years ago I heard of a case where an inspector cited a licensee for exceeding their internal action levels in some area, even though they were well within regulatory limits.  I do not know how this was resolved but you could check the radsafe archives.

-----Original Message-----
From: RadSafe <radsafe-bounces at health.phys.iit.edu> On Behalf Of Chris Alston
Sent: Thursday, August 15, 2019 2:52 PM
To: AMRSO List <AMRSO-L at list.iupui.edu>
Cc: medphysusa at lists.wayne.edu; Radsafe List <radsafe at health.phys.iit.edu>
Subject: [ RadSafe ] Question for Legal Eagles + Associates

Folks

Can you elucidate for us the philosophy of regulation underlying the distinction between “limits” and “action levels”?  Does it have anything to do with which entities have the primary responsibilities for enforcement, that is, those on the regulatory end of the arena or those on the regulated end?

TIA.
ca
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