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RE: Recommendation for any dosimeter reported as Official Dose of Record
Sounds right to me, Sander. On the Department of Energy side, if you
use a dosimeter to demonstrate compliance with the regulations, then it
has to be accredited (or exempted).
Neill
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Stanford Dosimetry
www.stanforddosimetry.com
stanford@stanforddosimetry.com
360 293 9334
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-----Original Message-----
From: owner-radsafe@list.vanderbilt.edu
[mailto:owner-radsafe@list.vanderbilt.edu] On Behalf Of Sandy Perle
Sent: Tuesday, March 11, 2003 9:16 AM
To: radsafe
Subject: Recommendation for any dosimeter reported as Official Dose of
Record
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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