Re: over-regulation

[Dave Derenzo <dave@uic.edu>]

To All,

As an RSO at a medical/research facility, I have sometimes felt 
over-regulated too.  It seems to me that some regulations are nonsense, 
some are overly restrictive, and some make sense but are in conflict with 
other regulations that also make sense.  In some cases I feel a particular 
regulation is not restrictive enough.  Sometimes there are no regulations 
when there ought to be some.

Having seen things as a regulator, I can say that what many licensees 
actually do, especially medical licensees, have caused the creation of 
regulations that are being judged by radiation safety professionals as 
overly restrictive.  Remember, not all licensees have a real HP or they 
have an inexperienced one at best.  Hospitals frequently name a physician 
or a medical physicist to be the RSO.  Not all people who use radioactive 
material apply a great deal of common sense.  I am constantly amazed by the 
reasoning processes of some of the radiation workers that I encounter.  I 
would speculate that many of the regulations that have appeared over the 
years came about because of some actual or perceived problem that needed to 
be addressed.  When problems occur, regulators are frequently accused by 
politicians, news media, and the public of failure to adequately 
regulate.  Pretty tough situation, if you ask me, and it is not surprising 
that regulators are frequently in the "CYA" mode.

Lastly, and not to offend the medical community, I feel that some 
physicians are overly-sensitive to the regulatory process.  Collectively 
physicians are very powerful politically and have gotten their way in many 
radiation safety related areas that could use a little more unbiased 
regulation.  All too often I have heard objections to regulatory control 
based on interference with patient care when to me this is simply not the case.

I'm pretty sure everyone will agree that the regulatory process is not 
perfect.  I don't think that we should expect that it ever will be 
perfect.  Regulators should be more open to our concerns, and the regulated 
community should be more understanding of the pressures that cause the 
regulators to act.  All that we can do is to strive to work together, 
licensees and regulators, to optimize the regulatory situation.

Dave Derenzo

At 11:28 AM 07/19/2000 -0500, you wrote:
>Dear Bill,
>
>Medical HP IS over-regulated.  So are power plants.  And, in general,
>hospitals have few staff devoted to health physics.  In my opinion,
>over-regulation is when there are rules that provide no added margin of
>safety.  If most of the violations noted have trivial or no expected long-
>or short-term effect in terms of added risk to workers or the public, then
>it's reasonable to suspect that the underlying regulation is not really
>needed.  But, that's nothing we haven't heard before.
>
>Andy
>
>Andrew Karam, CHP              (716) 275-1473 (voice)
>Radiation Safety Officer          (716) 275-3781 (office)
>University of Rochester           (716) 256-0365 (fax)
>601 Elmwood Ave. Box HPH   Rochester, NY  14642
>
>Andrew_Karam@URMC.Rochester.edu
>http://Intranet.urmc.rochester.edu/RadiationSafety
>
>If a man never contradicts himself, the reason must be that he virtually
>never says anything at all.  (Miguel de Unamuno, quoted in "What is
>Life?" by Erwin Schrodinger)
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   _/    _/  _/  _/_/_/_/    Dave Derenzo, MPH  (Dave@uic.edu)
   _/    _/  _/  _/            Radiation Safety Officer
   _/    _/  _/  _/            University of Illinois at Chicago
   _/    _/  _/  _/            Radiation Safety Section, MC932
   _/    _/  _/  _/            820 S. Wood St., Chicago, IL 60612-7314
   _/_/_/_/  _/  _/_/_/_/  Voice:(312)996-7429  Fax:(312)996-8776
   ______________________  URL:  http://www.uic.edu/~dave


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information can be accessed at http://www.ehs.uiuc.edu/~rad/radsafe.html