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Re: Industrial Radiography Accidents
A few years ago, a tax provision made it cheaper for manufacturers to retool
their factories than to continue functioning as they were. The only way to
implement change is to create an impact on the affected parties' hot
buttons, which in many cases is their bottom line. You are exactly on the
right course. Write the regulations so that it's cheaper to purchase and
operate re-engineered equipment. Use a color system similar to what the NRC
uses for power plants--the more you're "caught" in compliance, the less
costly it becomes to operate. BTW, this approach also tends to erect
economic barriers to new entrants into the field, which reduces the number
of licensees in favor of those who have a long history of compliance, making
them easier to monitor and more self-regulating. I've already offered Mack
my other two cents' worth privately.
Jack Earley
Radiological Engineer
Enercon Services, Inc.
6525 N. Meridian, Suite 503
OKC, OK 73116
phone: 405-722-7693
fax: 405-722-7694
jearley@enercon.com
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----- Original Message -----
From: "Ted de Castro" <tdc@XRAYTED.COM>
To: "Richard, Mack L" <mrichar@iupui.edu>; <radsafe@list.vanderbilt.edu>
Sent: October 10, 2001 1:20 p.m.
Subject: Re: Industrial Radiography Accidents
> You are of course right and this is of course a very good idea! Even I
> thought of it - so it MUST be good!!! <grin>
>
> BUT - what you will hear back from the field is that this equipment is
> usually un powered! Made to be used in ANY field conditions. Also -
> the equipment is treated VERY badly - thus why sources so often stick in
> the guide tubes (kind of like portable x-ray machines are treated in
> hospitals!).
>
> There is a great resistance to change in the industry! For the very
> occasional need for flexibility of free operation - they want the
> cameras ALWAYS unencumbered by any sort of safety "accessories". IF
> they were put on - they would be quickly be "accidentally" broken off.
>
> I am on the ANSI writing committee for the OPERATIONAL standard for
> industrial radiography and it is VERY frustrating. The controls are ALL
> administrative because the equipment is SO primitive!
>
> Realize - if a phosphor were put in the shield right up next the the
> parked source and the light were light piped out through twists and
> turns in the shield - there would be enough light for a very clear and
> non powered (or self powered if you will) indication that the source was
> indeed parked.
>
> Even that would meet with resistance.
>
> Like I said - its frustrating. I don't even bother to offer suggestions
> any more!
>
> I'm glad we don't do that here - and seldom have radiographers in.
>
> I think the solution MAY be in making some regulatory tradeoffs -
> instead of the "pile it on" method currently used.
>
> For instance. For standard equipment - shorter license periods, more
> inspections, more record keeping, more training and more often. BUT -
> IF they have an indication device such as you suggest - or the phosphor
> method I mentioned - BACK OFF on the above.
>
> Unfortunately in today's regulatory atmosphere - the rules put in place
> by lawyers stay in force - no matter what more advanced and secure
> methods you use.
>
> I look at it this way:
>
> Under current regs an operation using ONLY administrative controls is
> permitted - while recognizing that engineered controls are better and
> suggested. THUS stating that administrative in lieu of engineered
> control is acceptable.
>
> YET - an operation with total engineered controls is NOT acceptable -
> thus engineered controls in lieu of administrative controls is NOT
> accepted.
>
> So - why bother to spend the money on and suffer the limitations of
> engineered controls!
>
> "Richard, Mack L" wrote:
> >
> > Radsafers:
> >
> > First, please understand that I have limited knowledge/experience with
> > industrial radiography. I've seen the sources/shields (as I recall the
> > radiographers referred to these as "cameras") and have a basic
understanding
> > of how they function. With that disclaimer out of the way, I wonder if
some
> > modifications to these cameras might help prevent some of these
overexposure
> > problems.
> >
> > It seems that in a number of overexposure cases I've read about, the
> > radiographer fails to perform a radiation survey after the source has
> > supposedly but unsuccessfully been retracted into the shield. Whether
the
> > failure is forgetfulness, negligence, pending tee time, etc., the result
is
> > the same. Someone stated that these devices have some type of indicator
to
> > advise the radiographer of the source position. While not explicitly
> > stated, I assume that to mean either a mechanical or electro-mechanical
> > device (i.e., it doesn't actually measure radiation).
> >
> > Here's a thought on a solution to this problem. Would it not be
possible to
> > place some type of detector on the side of the shield where the source
exits
> > the shield that would be connected to a flashing light to indicate the
> > presence of elevated levels of radiation? One could even configure the
> > "on-off" switch so that when the source guide tube is connected, it
> > automatically turns the detector on (that prevents the radiographer from
> > forgetting to turn on the detector). Of course, a "threshold" level
would
> > have to be set to prevent the detector from activating the flashing
light
> > due to radiation shining through the shield. Since this would have to
be a
> > battery powered detector, one would also like to see some type of
audible or
> > visual warning if the batteries are low.
> >
> > Granted, as the source is extended away from the shield through the
guide
> > tube, the detector may quit flashing due to a reduction in radiation
> > intensity. Thus, if the source became detached in the guide tube at
some
> > distance from the shield, there would be no indication of a problem.
> > However, the radiographer would know something was amiss if the light
didn't
> > begin flashing as he retracted the source back into the shield. Given
this
> > drawback, such a device shouldn't replace the post irradiation survey.
> >
> > This idea is similar to what we utilize when we perform "high dose rate
> > (HDR)" brachytherapy. HDR brachytherapy involves remotely threading a
10 Ci
> > Ir-192 source through a catheter (thin plastic "guide" tube for you
> > non-medical types) into a specific area of a patient's body (e.g.,
tumor).
> > This is necessarily performed in a shielded room. Although the HDR
console
> > indicates the status of the source position, we are required to have a
> > separate monitoring system that monitors the radiation in the room to
> > independently indicate the presence/absence of radiation in the room.
At
> > the end of the treatment, we perform a survey with a portable survey
> > instrument before we take the patient out of the treatment room.
> >
> > It seems that such a system might help to prevent these overexposures
> > (unfortunately, nothing is 100%). Perhaps such a system would be cost
> > prohibitive or not compatible for the various camera configurations. As
I
> > said, my knowledge of industrial radiography is limited and sometimes
> > ignorance is bliss. I won't be offended if someone comes up with a
laundry
> > list of reasons why this won't work.
> >
> > Just my 2 cents worth (see, you may have gotten what you paid for).
> >
> > Regards,
> > Mack R.
> >
> > Mack L. Richard, M.S., C.H.P.
> > Radiation Safety Officer - IUPUI/Indiana Univ. Med. Cntr.
> > Phone #: (317) 274-0330 Fax #: (317) 274-2332
> > E-Mail Address: mrichar@iupui.edu
> >
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