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Re: hospital contamination incident



In a message dated 01/08/2003 10:55:51 AM Pacific Standard Time, liptonw@DTEENERGY.COM writes:

I must repectfully disagree.  The purpose of regulation is NOT to punish consequences but to prevent them.  "Forgetting procedures" is definitely an accident precursor and cannot be tolerated. Your argument is the same as saying that the police should not issue a ticket to a motorist who runs a Stop sign or a red light, as long as there's no accident.



Now, I must respectfully disagree.  The potential consequence of running a red light is death to the cross-traffic driver - that's pretty serious.  The potential consequence/risk of harm from moderate levels of contamination on a package of radioactive material emanating from a facility licensed for the use of common nuclear medicine isotopes is so small it cannot even be validly computed, if it exists at all.  The two situations are apples and oranges.  I believe performance-based/risk-informed enforcement is a step in the right direction, and, believe me, I'm not paid to say that.  It's a regulatory philosophy that has been sorely needed, and long in coming.

Barbara