Re: LNT/ALARA and workable regulations

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

While I am not promoting this as ALARA, at this point, I will mention 
that in some courts, ALARA has been deemed to be met by defendants by 
simply demonstrating that the plaintiff at no time ever exceeded a 
regulatory limit. Therefore, in some jurisdictions, the regulatory 
limits have been considered the "standard of care" to be met. 

I would also like to see ALARA concepts and philosophies removed from 
all regulatory documents, and return to regulations being 
prescriptive on measurable components only. Philosophy belongs in 
guidance documents, information bulletins, etc., and not in a 
regulatory document. It used to be that unless a facility committed 
to a guidance document, they could not be regulated against it. That 
seemed to change over the years. If the government wants to regulate, 
it should regulate what's in the regulations, and they should do 
whatever can be done to eliminate the subjectively from the 
inspector, where appropriate. By doing so individual's agendas can be 
reduced, if not eliminated all together.

Lastly, where there is no discernible evidence that demonstrates 
risk, by the preponderance of that evidence, regulations should be 
based on the "real" risks, and not the "perceived" risks. It's about 
time eliminate the "feel good" regulations, and bring reality to the 
regulatory process.

------------------------------------------------------------------------
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

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