Re: civil penalty for medical violation

[OFFTOWY@aol.com]

Well, if anyone understood my post to advocate non-compliance with 
inconvenient rules, I guess I need to remember that sarcasm does not 
translate well through e-mail.

Anyway, this brings up an interesting subject.  Obviously the regs have 
filled up with fluff over the years, probably in response to various isolated 
events.  And that is just the rules themselves - does anyone believe that 
most of the guidance documents are not de facto rules also?  Has anyone ever 
considered approaching the regulatory agencies with a request for rulemaking 
to roll back some of the more onerous requirements?  Has anyone done a 
relatively well justified cost/benefit analysis to identify the requirements 
that seem to have no significant basis?  If we are going to live with ALARA 
as a regulatory requirement, why not make the regs pass muster under that 
same requirement.  (Of course, ALARA might be the first one to go.)  If it is 
not worth doing, let's go to the rulemakers and get rid of it.

The process does exist - are they open to this sort of thing?  Is this a good 
role for one of our societies?  The rules would seem to lie at the heart of 
promoting safety.

Lew LaGarde
offtowy@aol.com
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