Notice of Praise

["Grimm, Lawrence" <LGrimm@ADMIN.UCLA.EDU>]

In response to Bill Lipton's comments:

Bill:

You have good points in your posting.  I hope you saw my later posting
(accidentally to Radsafe, but oh, well).  As I noted, I have no illusions
about the concept - both in its underlying philosophy, and in its
implementation.  It can be fraught with problems, which are not
insurmountable in my opinion.  

I used to be a regulator, so I thoroughly understand the disinterested party
concept. I could give you a dissertation on the theory of the relationship
of regulators, the regulated and third-party interveners from my Public
Administration education, but I'll just leave you with my feelings - I think
the disinterested party concept is stupid, a myth, a facade, and exists only
to mollify the third party interveners.  If I ever get back to finish
working on my Master of PA,  I would like to do a dissertation on the
subject.  The theory behind it all needs serious work.

With my feelings aside and presuming the disinterested party concept is
valid, I beg the following question.  Does the concept that I propose,
giving Notices of Praise, necessarily compromise the disinterested party
concept?  In considering the question, I believe there are two factors that
must be carefully analyzed: 1)is there an actual compromise of the regulator
in the process?; and 2) can there be a perceived compromise?  

If the process is properly structured, such as taking into account the
concerns you mentioned, it is relatively easy to demonstrate that there
would be no actual compromise.  For example and in a very real sense, the
regulators already give praise when they issue a letter of "no problems
found", or issue a license.  It is the regulator's backhanded way of saying
someone is doing well.  A Notice of Praise would only put a positive spin on
the situation (with all of the benefits that fall out from treating people
nicely instead of being the cold fish that regulators are "required" to be
under the disinterested party concept). Additionally, there is nothing in
the Notice of Praise concept that says a regulator cannot take back the
praise.  I had a situation once where I praised a lab for something, and two
weeks later I was hammering them on a different issue. Actual compromise is
a function of how the regulator is educated to manage the licensee.  You and
I were taught to handle them analytically and to be "disinterested" parties.
You do not get emotionally invloved and you avoid emotional involvement at
all cost.  I believe that this can still be applied to the Notice of Praise
concept.  The only added factor is that when you analyze the licensee, and
see a good job done, you say so publically (you know we all do it privately
now anyway).  The concept that I propose is not an emotional concept, it
still relies on analyzing the licensee.  

The second question concerning perceived compromise is also easy to answer:
of course there would be those who perceive it as compromising the regulator
and the disinterested party concept. Who might they be?  You know as well as
I that it would be the same people who already believe (and use it as a
tool) that regulators are compromised through their interactions with the
regulated (the cozy partners theory).  I believe that there would be no need
to change the same methods employed today that we use to handle allegations
of compromise. Personally I hope we can improve on those methods - but
that's another dissertation.  Such allegations occurred in the past, are
prevalent today and will be there in the future. My thought is that the
Notice of Praise concept is designed to reach the 95% of the population who
usually could care less.  It is designed to demonstrate a positive side of
radiation users.  It is designed to show that as an industry, we are doing a
good job - which I believe we are.  

An analogy to this concept comes from my soccer referee experience (roughly
1200 games, instructing and assessing 100's of new referees, and personally
being assesed by some of the top referees in the US).  Typically, the new
referee knows the rules and tries to apply them to the best of his skill and
as a disinterested party.  Invariably he/she will do a game where they are
charged with being biased, and rarely is that the acuality.  For example,
the referee may assess more fouls to one team which were valid and without
bias, but the one team claims bias.  In this case, the perception of the
"offended" team is the problem.  On the other hand, the experienced referee
does not just apply the rules.  He/she manages the game, and it is an art
like any management practice.  Rarely will you see an experienced referee
get charged with being biased (please, no anecdotal stories to the
contrary).  My point: the poor, inexperienced, or chickenhearted
HP/regulator will just apply the rules.  A good regulator, an experienced
regulator should do more than just apply the rules. He/she should find ways
to manage the licensee.  

I have worked with a number of good regulators and when I analyzed why they
were good, I found that yeh they knew the regulations well, but mostly it
was because they were artfully managing me.  I appreciate it.  This Notice
of Praise concept is a tool to help practice the art of management.  My
experience has shown that it opens lines of communication, opens education
opportunities and most importantly it improves safety.  Is this latter item
not our bottom line as HP's and regulators?  

Best wishes to all.


        Larry Grimm
UCLA Radiation Safety Division
*	On Campus: CHS A6-060 MS 957061
*	Off Campus: UCLA Radiation Safety Div, 2195 West Medical
Building, Los Angeles, CA 90095-1764
*	lgrimm@admin.ucla.edu   Phone:310/206-0712   Fax 310/794-5825
*	If this email is not RSD business, the opinions are mine, not
UCLA's.
    
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