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Re: radiography - deja vu all over again
While we definitely need better enforcement, I try to avoid "zero tolerance"
policies, for several reasons: (1) They are unfair to a good person having a
bad day. (2) They encourage coverups. (3) They tend to be a subsitute for
correcting program weaknesses.
The incidents are generally the "tip of the iceberg" for a weak program.
Program elements I'd look at include: (1) training - Is the training relevant
and challenging? Is the exam valid? Are those who fail the exam properly
remediated? (2) procedures - Are procedures valid and maintained? Is
feedback on procedures encouraged and incorporated into procedure revisions?
Do workers have current revs of the procedures they need. (3) Supervision -
Do supervisors demand strict compliance with safety procedures? (I would
guess that in many organizations, supervisors emphasize production and give
the message to their workers that they don't really care whether procedures
are followed; just don't get caught.)
The opinions expressed are strictly mine.
It's not about dose, it's about trust.
Curies forever.
Bill Lipton
liptonw@dteenergy.com
John Andrews wrote:
> William V Lipton wrote:
>
> >Please see the attached item from the March 20, 2003, NRC Daily Event
> >Report. Here's another preventable radiography incident.
> >
> >my usual question: When is the NRC going to start taking radiography
> >seriously?
> >
> >Also, some key information seems to be missing from the report. The
> >sequence of events seems to be: (1) source exposed for shot, (2)
> >radiographer leaves work area prior to cranking back source, (3)
> >radiographer returns, changes film,and moves guide tube with source
> >still exposed. The report then states, "At this point, he realized that
> >his survey meter had pegged high, and remembered that he had not cranked
> >the source back in prior to moving it..."
> >
> >Assuming that TX regulations are similar to NRC regulations, consider 10
> >CFR 34.47(a): "The licensee may not permit any individual to act as a
> >radiographer or a radiographer's assistant unless, at all times during
> >radiographic operations, each individual wears, on the trunk of the
> >body, ... an operating alarm ratemeter..."
> >
> >I think it's just this scenario that the regulators had in mind when
> >they required an alarm ratemeter. Where was it?
> >
> >
> After the second overexposure in our radiography crew, our management
> made some changes and I was the lucky guy to take over the program. I
> made it especially clear that if the radiographer or assistant was found
> performing radiography without wearing the newly mandatory required
> Eberline Rad Tad, he would be promptly be fired. We still had problems,
> but we had no further excess exposures. Suddenly the radiographers were
> aware of the source being exposed.
>
> John Andrews
> Knoxville, Tennessee
>
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