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NRC Information Notice 2002-28



NRC Information Notice 2002-28, "Appointment of Radiation Safety

Officers and Authorized Users Under 10 CFR Part 35 ['Medical User of

Byproduct Material']," was issued on September 27, 2002.  In this

Notice, the NRC notes that, "Several recent NRC inspections have

identified cases involving medical licensees who appointed an RSO

[Radiation Safety Officer] or AU [Authorized User] without this

individual's knowledge or consent.  As a result licensed activities were

performed without the oversight of an RSO and dosages were administered

to human patients without the supervision of an AU."



The Notice goes on to state that 10 CFR 35 is being revised to required

an RSO to accept his responsibilities in writing, and also requiring an

AU to supervise individuals using licensed material.  This seems to be

the regulatory equivalent of requiring you to open a door before

attempting to walk through it.



This would be funny if it weren't so sad.  In Radsafe, Congressional

intervention, and, I'm sure, other forums, the medical community has

been preaching that they don't need NRC regulation.  Unfortunately their

actions are requiring ever more detailed micromanagement, for which

they'll probably blame the NRC.



This is an example of what happens when licensees decide to not go

beyond following the letter of the regulations, forcing the regulator to

make the regulations "good enough."



I'm reasonably confident that most medical licensees do not engage in

such practices.  However, as the power industry has learned, if you

don't regulate yourself, the regulators will be forced to make their

regulations "good enough."  Unfortunately, they'll probably find that

"good enough" for the regulators does not provide for efficient

operation.



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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