[ RadSafe ] Re: OSHA Federal Register Notice

[BLHamrick at aol.com]

In a message dated 5/4/2005 8:48:43 P.M. Pacific Standard Time,  
vargo at physicist.net writes:

The  existing 29 CFR 1910.96 is hopelessly obsolete, as it is largely a
mirror  image of the 1963 version of 10 CFR 20 - right down to 5(N-18)  and
quarterly limits.  There are a number of Federal activities,  particularly in
the homeland security, transportation security, customs,  and border
protection in which the use of ionizing radiation has expanded  tremendously
and I think OSHA has a responsibility to take a fresh look at  these
activities.  It would certainly be appropriate for OSHA at the  very least to
harmonize its standards with the 1987 Presidential Guidance  and the 1994
version of 10 CFR 20.


Yes, that would be appropriate, at the very least.
 
I believe Clayton's earlier characterization was apt.  It appears OSHA  is 
trying to reinvent the wheel.  I think their call for public opinion on  some of 
the issues they're trying to address is like taking a public opinion  poll on 
how to perform brain surgery, or calling for a vote on whether or not  the 
world is flat.  It appears somewhat naive to me, and that makes me a  little 
nervous, not as a regulator, but as a citizen who will end up paying for  this 
escapade.
 
Barbara