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Re: Radiography HP
I appreciate the opportunity. I don't have any quick fixes, but I think I know
where to start looking.
I. My observations
a. Some Agreement State programs are better than others.
b. Most radiography licensees perceive ("perception is reality") that they have
little to fear from their regulators, i.e., inspections are rare and when a
violation is found the fine is a nominal "cost of doing business."
c. This is a competitive, if not cutthroat, business, with an emphasis on
productivity and no perceived (there I go, again) benefits from enforcing a
safety culture. Thus, a radiographer who takes the time to survey the work area
will be penalized for reduced productivity and even harrassed if he raises
safety concerns.
d. I suspect that the reported incidents are just the tip of the iceberg. A
radiographer who screws up may be unofficially encouraged to "forget about it."
and is likely to be disciplined if he reports an incident on himself, or
harrassed by coworkers if he reports someone else's incident.
II. The regulators should:
a. Benchmark the good Agreement State programs to see what works.
b. Devote more resources to inspections. Areas that need to be inspected
include:
(1) training - What is the quality of the training? (Don't just look at the
lesson plans; talk to the rad workers to see if they understand the
requirements.) Is the exam valid? (Does it cover all the important areas? Is
it sufficiently challenging?) Is the exam secure? (I visited one licensee
where the same exam had been used for so long, I doubt it had any validity.) Is
the trainee required to review wrong answers and understand why? How are
failures remediated? (I suspect that it's common to give a trainee the same
exam over and over until he passes.)
2. procedures - Are the procedures usable and valid? (I sometimes run into
procedures that are years old and still rev. 0; a sure sign that they're
ignored.) Are the radworkers knowledgable on the procedures? Talk to them. Do
they even have the procedures with them on a job? Does the licensee have an
effective corrective action program.
3. dosimetry and instrumentation - Is this maintained and calibrated? Do the
workers know how to perform required operability checks? Are the records in
order? Are "lost" dosimetry cases investigated? (It's often convenient to
"lose" your dosimetry if you think you've screwed up.)
4. observe work at remote sites - Although employees will generally be on their
best behavior if an inspector's around, sometimes they just don't care.
c. Take meaningful enforcement action for violations. Fines are often seen as
the cost of doing business. Poorly performing licensees should not be in
business.
d. This is a tough one, especially for me, but there should also be a system to
hold the customers accountable for the safety of their radiography contractors.
Right now, the organizations employing radiographers are generally not
responsible for radiography violations at their facilities. Thus, they
generally don't audit their radiographers' safety programs; all they care about
is adequate films at the lowest price. This attitude is transmitted to the
radiography vendors, who often perceive (I did it, again.) that resources
devoted to safety are unproductive. This is NOT the case in the hazardous waste
business. If a hazardous waste TSDF screws up, the waste generator is also held
responsible. Thus, companies are a lot more careful about whom they deal with.
This approach has to be adopted for radiography.
I hope that I wasn't too rambling. Don't hesitate to contact me with additional
questions.
The opinions expressed are strictly mine.
It's not about dose, it's about trust.
Curies forever.
Bill Lipton
liptonw@dteenergy.com
"Perrero, Daren" wrote:
> What do you perceive as the major problems? What are your suggestions for
> correcting them?
> I am all ears.
> The thoughts expressed are mine, mine, all mine!
> I'm with the government, I'm here to help........
> Daren Perrero, Health Physicist
> perrero@idns.state.il.us
>
> -----Original Message-----
> From: William V Lipton [mailto:liptonw@DTEENERGY.COM]
> Sent: Thursday, May 30, 2002 5:55 AM
> To: AndrewsJP@AOL.COM
> Cc: tdc@XRAYTED.COM; HustonThomasE@UAMS.EDU; RADSAFE@list.vanderbilt.edu
> Subject: Re: chirper
>
> So let's stop looking for the Blue Light Special on chirpers, and talk about
> how we can get the regulators and licensees to take radiography hp
> seriously.
>
> The opinions expressed are strictly mine.
> It's not about dose, it's about trust.
> Curies forever.
>
> Bill Lipton
> liptonw@dteenergy.com
>
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