[ RadSafe ] Re: OSHA Federal Register Notice

[George J. Vargo]

Barbara,
 
As usual, your assessment is penetrating, accurate and succinct.
 
I suspect that some of the apparently naive nature of the questions stems
from OSHA being an organization that only deals with ionizing radiation on
the fringe (i.e., there are relatively few activities that actually fall
under their jurisdiction once one subtracts, NRC, DOE, and state-regulated
activities - what's actually left? Ok, TENORM in some cases, maybe the VA
and DHS, but, realistically, what else?) and a likely genuine concern to be
transparent and inclusive in any potential rulemaking.  Asking the same
question several different ways covers them, because they can claim to have
cast a wide net and it keeps the JDs happy (really - no offense intended!)

George J. Vargo, Ph.D., CHP 
Senior Scientist 
MJW Corporation 
http://www.mjwcorp.com <http://www.mjwcorp.com/>  
610-925-3377 
610-925-5545 (fax) 
vargo at physicist.net 

-----Original Message-----
From: BLHamrick at aol.com [mailto:BLHamrick at aol.com] 
Sent: Thursday, May 05, 2005 00:45
To: vargo at physicist.net; radsafe at radlab.nl; clayton.bradt at labor.state.ny.us
Subject: Re: [ RadSafe ] Re: OSHA Federal Register Notice



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