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RE: radiography - deja vu all over again
With the exception of a few pointed comments (unfortunately), there has been
some very good dialogue on the topic. As with many areas, one argues over
the proper balance.
As I see it, the problem is not that, for example, that someone received 10
rads, increasing their chances by ~0.1% of getting a terminal cancer. This
whole field is so heavily regulated compared with other fields (are there
regulators there when your spouse uses a chemical cleaner?) that most
stupidities and mistakes at least get reported for all to see. This is good,
at some level (ours), but it tends to hurt the industry as a whole -
especially when it provides fodder for the anti-nuke establishment.
Also, we so often forget that people can do dumb things at any time,
irrespective. Being proactive at the regulatory front is no substitute for
being competent, methodical and careful when dealing with radioactive
materials. I think that promoting the proper attitude, and ensuring that
those who are so-licensed must adopt it as well, seems key here. Note that,
in many businesses, it is typically a company policy that two qualified
people be present during hazardous maneuvers. The same might apply when
dealing with hazardous sources. There is typically a lack of common sense
that permeates most such issues. Two heads do tend to be better than one
when coupled with the right personality type. The attitude must be promoted
by both the regulators and the industry as a whole.
Grant
-----Original Message-----
From: William V Lipton [mailto:liptonw@DTEENERGY.COM]
Sent: Wednesday, May 21, 2003 2:14 PM
To: Grimm, Lawrence
Cc: radsafe@list.vanderbilt.edu
Subject: Re: radiography - deja vu all over again
The message in both of your posts seems to be that there's nothing more that
the regulators can do, and that I'm "reactionary, ignorant, and
irresponsible" for suggesting otherwise.
I think I've said all of this, before, but recognizing that my communciation
abilities may be almost as bad as yours, I'll try again.
I think that 10 CFR 34 is a good regulation. The problem is that
enforcement seems to be reactive rather than proactive, i.e. they slam
anyone who's unfortunate enough to screw up (and get caught), but do not
seem to identify and address the root causes of the problem.
Although the proximate cause for most of these incidents is an individual
failure, this is probably the tip of the iceberg; just a symptom of
organizations for which safety is a low priority. Enforcement should be
concentrated at the program level, to catch violations before they lead to
full scale incidents. Here are some thoughts:
1. It seems that some Agreement State programs are better than others. The
NRC should look at this, and benchmark the best programs.
2. training - Another Radsafer described a situation where an individual
who failed the exam was coached thru the same exam to pass. I've seen a
similar situation. The NRC should look at exam content and validity. It
may be necessary to require radiographers to pass a NRC (or Agreement
State)-administered exam.
3. procedures - The NRC should review licensee procedures to assure that
they are current and valid, that there is a program to incorporate
radioagrapher comments, and that all radiographers have current copies of
the procedures they need.
4. safety culture - I admit this is a tough one. You can't dictate
attitude. I would suggest that all licensees have an ombudsman program,
where all employees have confidential access to an individual who can follow
up on safety concerns. One of the problems seems to be the time pressure,
which is really a reflection of cost pressure. Effective enforcement would
take away the cost advantage of cutting corners.
When I ask, "When will the NRC take radiography seriously?" I'm really
asking the NRC to devote the resources necessary to fix this problem.
If this is your definition of "reactionary, ignorant, and irresponsible,"
then I'm guilty as charged.
The opinions expressed are strictly mine.
It's not about dose, it's about trust.
Curies forever.
Bill Lipton
liptonw@dteenergy.com
"Grimm, Lawrence" wrote:
> Dropping the sarcasm of my previous post, here's a serious reply.
>
> The NRC recognized the problem of industrial radiographers (IRs) at least
30 years ago. IRs as a group had more overexposures than any other group of
radioactive material users, and probably still do. The NRC implemented all
sorts of regulations specifically aimed at the IRs. The NRC implemented IR
training courses for NRC and agreement state inspectors - which I attended
in 1979. It is a very good course. The NRC created an excellent book/guide
for IRs. I would argue that the regulatory bodies are most cognizant of the
problem and work hard to decrease the problem.
>
> When one studies the problem, it is evident that almost all the
overexposures are related to an individual failing to follow the rules.
There are a lot of factors for this happening. IRs work in horrendous
environments. They are always under pressure to get the work done and often
have to work when no one else is around, i.e. after midnight. They spend
days and weeks on the road, sleeping in fleabag motels. They tend to be a
rough and tumble lot, and there are not too many Ph.D.'s in the crowd. As
an indication of how rough they can be, I know a State inspector who was
shot at by an IR.
>
> I beg the question of, "What more can the regulators do?" I would say, not
much. How do you stop an individual from doing something stupid? Short of
implementing my sarcastic recommendations for rules, I believe the
regulators have done a good job of trying to solve the problem.
>
> What troubled me about the Radsafer's post was the reactionary,
"call-to-arms" indicating the NRC was not doing enough. This type of
reactionary, ignorant (of all facets of the problem) behavior is
irresponsible for a HP. It is typically the irresponsible behavior of a
politician or an anti-nuke person, but should not be the behavior of a HP.
>
> Larry Grimm
>
> If this email is not RSD business, the opinions are mine, not my
employer's.
>
>
>
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