[ RadSafe ] Re: OSHA Federal Register Notice

[BLHamrick at aol.com]

In a message dated 5/4/2005 10:06:36 P.M. Pacific Standard Time,  
vargo at physicist.net writes:

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!)



Thank you, George, and don't worry, I'm quite used to the lawyer  "jokes."
 
I agree that OSHA has generally dealt with "fringe" ionizing radiation  
issues, which is all the more reason they should have turned to the expert  
agencies, NRC, DOE, (and, yes, I admit, even) EPA to work with them to integrate  
their program and concerns with the other programs.
 
More importantly, I believe, with respect to these specific regulatory  
issues (NARM and X-ray), they should have turned to the Organization of  Agreement 
States, and Conference of Radiation Control Program Directors for  dialogue on 
how these sources and worker exposures are currently being managed  by the 
State Radiation Control Programs.
 
And, I still think it is questionable, even irresponsible, to ask the  
general public for answers to highly technical questions.  One will  invariably get 
back far more chaff than wheat with that approach.
 
Barbara L. Hamrick