Re: Scaling back regulations

[OFFTOWY@aol.com]

I am aware of some of the regulatory activities in other arenas, specifically Part 50.  I guess was wondering if anyone has considered any corresponding activity in the licensing and occupational radiation protection arenas.  I mean, sit down and read Parts 30-36 some time.  Does anyone really understand all of that?  And there are Parts 20 and 835 (yes, and parts 19, 21, 40, 50, 61, 71, 820, 830, etc.  I do not mean to slight anyone).  I would suggest that perhaps a rad safety regulation might provide adequate protection if it required an RPP, prescribed dose limits, and required that the workers be provided adequate information and controls to ensure those limits are met.  The exact management tools that are used to meet the requirements (training, posting, labeling, physical controls, etc.) could be established in the RPP.

The current system is built for the regulator, not the licensee.  We can probably all agree that a dose exceeding the limits is significant from some safety perspective.  The current system focuses on identifying and punishing precursors to such events (and precursors to precursors).  Maybe, just maybe, if nobody exceeded a dose limit, an event really has no particular safety significance and should not be a violation of Federal regs.

Standardization has advantages, but maybe that should be in the realm of the standards orgs, not the regulators.  I hate the California new-age management-speak, but maybe it is time for a new paradigm.

Lew LaGarde
offtowy@aol.com
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