Update - state regulations - quarterly film requirements

["Sandy Perle" <sandyfl@earthlink.net>]

First of all let me thank Cynthia, Walter, Matt, Paul and Dave for 
providing me with information regarding the current regulatory 
environment in their state. Cynthia provided new information to me 
where not all of NY state imposed limitations on quarterly film 
monitoring. The state of IL does not categorically state this within 
the regulations, but still requires monthly film. I am not sure if 
this is acceptable, without there being a specific regulation. The 
state does have instructional sets  which I have been trying to find 
on their site. I would think that instructional sets can not and 
should not contradict what's in a regulation, similar to Reg Guides 
(unless made part of the license) can't be used to make regulation, 
within the NRC world.

I also spoke to a supervisor in Texas, and learned that they do not 
prohibit quarterly film monitoring. The individual told me that the 
hospital licensing board had a statement about monthly film, and that 
they have met asking that their licensing certifications be 
consistent with the state's regulations, since the radiation 
protection department did not have any concerns for a facility 
wearing a quarterly film. 

Again, I've learned some new information, and thank everyone for 
providing the information. 

Paul Lavely suggested that I contact the CRCPD Council of Rad 
Protection Program Directors, providing them documented data 
supporting quarterly film. In that way, perhaps all states can come 
to a consistent policy for rulemaking. That was an excellent 
suggestion. Per Walter's suggestion, my staff is providing FL with 
the necessary documentation to allow quarterly film to be used in the 
Safety Requirements for Possession and Use of Sealed and Unsealed RAM 
program. 

In conclusion, I firmly believe that only Radiographers who wear a 
film dosimeter should be restricted to a monthly wear period. It was 
comforting to see that except for a couple of states, all currently 
accept quarterly film.

Thanks again to all those who responded, and to those who will 
respond in the future.

------------------------------------------------------------------------
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 				                           
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Costa Mesa, CA 92626                                      

Personal Website:  http://www.geocities.com/capecanaveral/1205
ICN Worldwide Dosimetry Website: http://www.dosimetry.com

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