RE: intentional misuse - proposed "cures"

["Pete Collopy, CIH,CHP" <pcollopy@mjwcorp.com>]

Andrew (and others),

I snipped out your reply to save a few electrons.


While I have a great deal of respect for Bill (who is in the running for
radsafe gadfly of the year) this is a classic case of "if you haven't been
there you have no idea (or perspective)." I have worked (and managed -
emphasis here) in almost every type of rad environment (hmm maybe I can't
stay employed in one place long enough - but I digress) so I have made my
fair share of mistakes which have taught me one important lesson - "one size
does not fit all !".

I agree whole heartily with Andrew. It is not just the University
environment either. I consult for some companies who use materials (at a
very low level and risk) as a small fraction of their actual business
activity. Recently, another HP consulting firm came in and did an audit of
one of my clients and scared the "crap' out of my client. In reviewing their
recommendations it looked like a laundry list from a power reactor audit. In
addition to some unworkable recommendations they had mis-interpreted a
number of 10CFR20 requirements. Luckily the NRC visited the facility several
weeks after the audit and found their recommendation to be "off the wall" as
applied to this facility. Ahh credibility restored.

The point is that the regulations and their application should be
commensurate with the risk. There is a great deal of freedom in the regs
(regardless of what the anal retentive types think). A good HP manager runs
a program that meets the regulatory requirements. An excellent HP runs a
program that makes people and the environment safer and the entire safety
operation an effective partner of the other facility units/departments. The
more integrated into the facility culture the better.

Bill's point about stress being the "root cause" may or may not be accurate
(Bill - I'll send you my take via private e-mail). Assuming it is accurate,
what steps does one take to remove or mitigate the root cause. Well the
first step would be to ask whether its worth doing. I think that any
solutions to this problem may end up invoking the law of unintended
consequences, of which Andrew has stated several. Given the number of
researchers using radioactive material the number of events certainly aren't
of epidemic proportions (unless they have changed the definition of
epidemic). Will the university and the environment be safer - not
materially, will research suffer - probably because all the PHD loons who
would fail an MMP are the same ones who make great discoveries. Those of us
in the norm are here for the dog work (and the beer).

When these events happen its actually an opportunity to do several things.
First, its a chance for the EH&S people at a University to emphasize to the
researchers how they need to know what is going on in their labs and how
untoward events (chem, bio or rad) may cause their work and that of other
researchers to suffer. Second, its an opportunity to explain to the public
that while these events are not good they are also rare and not
catastrophic. I believe if explained properly, the public understands why
you can't have chem or rad police in every lab and the steps the U takes to
weed out the poor performers (hopefully you have a demonstrated system in
place for positive behavior mod of the transgressors). Third, is for the
unaffected universities to get the press in and give them a  show and tell
on how the program operates with an explanation of what safeguards are in
place and what can fail. Of course if your local press person belongs to the
Sierra Club or others of extreme environmental religious beliefs this may
not be a good idea. If you get the press on your side ahead of time when an
event does happen you are ahead of the credibility game.

If all else fails, take some computer courses and switch occupations.

Pete C.

************************************************************************
The RADSAFE Frequently Asked Questions list, archives and subscription
information can be accessed at http://www.ehs.uiuc.edu/~rad/radsafe.html