Recommendation for any dosimeter reported as Official Dose of Record

["Sandy Perle" <sandyfl@EARTHLINK.NET>]

This is copy of a letter I posted to Powernet this morning. It is a 

follow-up to my recent request on EDs as dose of record, 

communication from Powernet list members, and, incorporates comments 

that I received in several communications with the NRC:



In my conversations with the NRC over the past few days, I have been 

told that to see any action by the NRC in the future, regarding the 

legal dose of record, that I need to send the information and request 

to Dr. Bill Travers, NRR's Office Director of the EDO.  



I do plan on writing to Dr. Travers and recommend that Section § 

20.1501be revised (current section provided below):



§ 20.1501 General.

(c) All personnel dosimeters (except for direct and indirect reading 

pocket ionization chambers and those dosimeters used to measure the 

dose to the extremities) that require processing to determine the 

radiation dose and that are used by licensees to comply with § 

20.1201, with other applicable provisions of this chapter, or with 

conditions specified in a license must be processed and evaluated by 

a dosimetry processor-

(1) Holding current personnel dosimetry accreditation from the 

National Voluntary Laboratory Accreditation Program (NVLAP) of the 

National Institute of Standards and Technology; and

(2) Approved in this accreditation process for the type of radiation 

or radiations included in the NVLAP program that most closely 

approximates the type of radiation or radiations for which the 

individual wearing the dosimeter is monitored.



I am going to provide documentation that supports revising the 

section to include that any dosimeter used to provide a legal dose of 

record require NVLAP accreditation. This will also include that any 

dosimeter used to report SDE-ME, be it from a wrist badge or a finger 

ring, that they too shall require NVLAP accreditation. It seems to me 

that if  a licensee is going to report a dose to a worker, and, that 

dose has to stand the test of time in a court of law, where the 

licensee has to validate the dose, then this will be facilitated by 

having a NVLAP approved dosimeter, through blind proficiency testing 

and an on-site assessment by a NVLAP technical expert. If you report 

it, then test it. The caveat in 1501 is that the dosimeter has to be 

"processed". We all know that with the current technology of EDs, 

they all have microprocessors and can and do have their internal 

parameters set by the facility. This is no different than changing 

the parameters on a TLD reader and with the specific TLD ECC. There 

is absolutely no difference.  



So, to bring all dosimeters into a Quality System, to include meeting 

15CFR285, ISO 17025, etc., I am going to request that any dosimeter 

used for a legal dose of record, that they shall be accredited.  



It's time to remove all of the exclusionary limitations. You want to  



report it, then accredit it.

-------------------------------------------------

Sandy Perle

Director, Technical

ICN Worldwide Dosimetry Service

ICN Plaza, 3300 Hyland Avenue

Costa Mesa, CA 92626



Tel:(714) 545-0100 / (800) 548-5100  Extension 2306

Fax:(714) 668-3149



E-Mail: sandyfl@earthlink.net

E-Mail: sperle@icnpharm.com



Personal Website: http://sandy-travels.com/

ICN Worldwide Dosimetry Website: http://www.dosimetry.com/



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