Sandy -
Florida also limits use of film badges for one month monitoring periods for its industrial radiographers, but the requirement has nothing to do with the limitiations of the badge, as we also require radiographers' TLDs and OSLDs to be exchanged on a monthly basis. We have this requirement because we want them to be able to monitor their doses more frequently. We don't have much faith in pocket dosimeter results, which can be off by up to 30% when properly calibrated. As you are aware, radiographers receive the highest doses of all nuclear workers (with the possible exception of cardiac cath), so we want them to keep a close track of worker exposures in order to identify unnecessarily high doses that indicate poor work practices, or worse yet, overexposures. The same philosophy applies to well loggers.
UInfortunately, Part XIII of our regulations (Rad. Safety Requirements for Possession and Use of Sealed and Unsealed RAM) also specifies that film badges and extremity TLDs must be exchanged monthly, so your point appears to be valid in this instance. We are revising our regulations, so if you are able to provide convincing documentation that this rule should be changed, please forward it to me (hard copies preferred). You may also want to call me directly to discuss this matter further.
Walter Cofer
Florida Bureau of Radiation Control
Bin C21, 2020 Capital Circle SE
Tallahassee, FL 32399-1741
(850) 487-2437
walter_cofer@doh.state.fl.us
-----Original Message-----
From: Sandy Perle [SMTP:sandyfl@earthlink.net]
Sent: Thursday, March 23, 2000 4:37 PM
To: Multiple recipients of list
Subject: state regulations - quarterly film requirements
I am currently updating my database on which states categorically do
not allow the use of quarterly film for occupational workers within
their jurisdiction. I am currently aware of only NY and TX. I would
like to know of other states who state specifically how long a
particular dosimeter may be worn (including TLDs, etc.)
The NRC does address this, specifically in 10CFR34.47(3) states
radiographers can not wear a Film for > 1 month.
It's unfortunate that the processing of film is regulated by a few
states based on the technology that existed 20 years ago or longer.
The technology is such that a film, when worn in an appropriate
working environment, can be worn and processed for up to 6 months
after the monitoring period. The regulators need to work their way
into 21st century thinking, and not base decisions on antiquated
technologies. Many states now recognize these advances, and only are
interested in ensuring that proper QA is applied, as for all
dosimeters. Even TLDs can be worn for up to a year without negative
effect.
I'd be interested in obtaining any information available.
Thank you in advance.
------------------------------------------------------------------------
Sandy Perle Tel:(714) 545-0100 / (800) 548-5100
Director, Technical Extension 2306
ICN Worldwide Dosimetry Division Fax:(714) 668-3149
ICN Biomedicals, Inc. E-Mail: sandyfl@earthlink.net
ICN Plaza, 3300 Hyland Avenue E-Mail: sperle@icnpharm.com
Costa Mesa, CA 92626
Personal Website: http://www.geocities.com/capecanaveral/1205
ICN Worldwide Dosimetry Website: http://www.dosimetry.com
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