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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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