re: Is two too many?

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

>On May 25, 2000, American Nuclear Insurers revised its External  
>Dosimetry Criteria recommending that insureds place TWO DOSIMETERS 
>ON EVERONE LIKELY TO EXCEED 100MREM PER YEAR - ALL THE TIME. 
I went back and read the original post. since I accidentally deleted 
it after I returned from Japan due to too many e-mails in my in-box. 
The above requirement isn't all that new. This was the requirement 
put forth years ago, especially in light of the push by many nuclear 
facilities to allow the use of the electronic dosimeter as dose of 
record. What ANI did was to allow any dosimeter be used as a dose of 
record, if permitted by the specific regulatory body, and, the use of 
a secondary device as a back-up. The secondary could be the same as 
the primary, or, be of a different configuration. The criteria was 
used after one particular nuclear utility (to remain confidential) 
fought ANI to only require a secondary dosimeter if the individual 
would exceed 300 mrem in the year. ANI's position was that 100 be 
used, or, if the utility elected to stay with 300 mrem, that ANI 
would not defend them in any potential litgation.

The reasoning behind the secondary dosimeter is solely for litigation 
and documentation of dose, in the event the primary is lost, or the 
dose is degraded, becoming questionable. There is no technical basis 
for the secondary device, unless the individual is expected to 
receive a measurable dose, which is within the procedural 
requirements of the facilities procedures. The dose, if need be, can 
always be calculated, and used as official dose of record.

The term AT ALL TIMES needs to be defined. I expect that this means 
any time an individual enters a radiation controlled area. However, 
as I stated at the onset, this has been the requirement for many 
years. So, I don't know what is new in this May statement.

I will be seeing Jerre Forbes at a meeting this week (if he attends), 
and I will ask him what has changed. At this point, I don't see any 
change in their position at all, until I read the entire document, 
once I am back in my office next week.

------------------------------------------------------------------------
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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Personal Website:  http://www.geocities.com/capecanaveral/1205
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