Re: On the Soapbox

[JMUCKERHEIDE@delphi.com]

Dan,

I don't think we are missing the point. There is no question that what you
say is true: A significant, costly effort could be involved in cleaning up 
a broken sign. 

But, the larger point is directly the conclusion you reach: this cost and
effort may be required by the regulator though it may be related to a
negligible radiation exposure! That is the point. We are _required_ to
undergo this cost, imposed by regulators, with no public health and safety
benefit. 

And your further point is even more telling: We will get great PR grief.
But, that grief is driven by the false public perception that the radiation
risk which you recognize as essentially insignificant (as the Warren
Sinclair quote about 'linear, and negligible at low doses' would indicate).
This false public perception is reinforced by the very fact that the HP
reaction to this incident would _clearly indicate_ that the risk is serious
(no rational response would expend significant resources for a non-problem)!
It must be significant!

You, and all of us in the formal business of providing for public safety,
contribute to this misperception by the very acceptance that such a response
would be required, without objection to the constantly ratcheting regulatory
initiatives that require such a response.

All of this is true _even before_ you address the lack of actual validity of
the linear dose "model". The linear dose model is ok as a conservative basis
for bounding considerations. But as the Warren Sinclair quote indicates: It
should be treated as negligible at low doses. Such a conclusion means that
you would _not_ expend these resources for this problem; nor for the entire
regulatory scheme which is directly causing the expenditure of $100s of
millions, and failing to provide for waste management, and preventing the
beneficial application of nuclear science and technology, for NO public
health and safety benefit.

I decry that instead of responding to the regulator on the inappropriateness
of the requirements, the response you propose is to further eliminate a
useful nuclear technology application, and lose a public safety benefit, in
the name of the costs, both financial and PR, being imposed by the rules and
the larger message that such small potential exposures have adverse public
health consequences. As long as you understand that, as the nuclear
technology applications are killed by this kind of response, the HP will be
as needed as railroad fireman in the diesel locomotive. (But I doubt that
your "union" will be as able to carry your job into the future as they
were.)

I ask that you reconsider the nature and direction of your response to such
issues. If the radiation risk is negligible, and in your reasoned assessment
of the choice of using tritium signs, with the real financial risks you
correctly describe, because of the rules that you find could require you to
undertake such costs, it would be better to complain about the rules than
abandon the techology. You should also advise your management, and the
vendor, and others (including the radsafe band of fellow travelers on this
journey), to contribute to the questioning of this growing insanity and
self-defeating bureaucratic nightmare.

Sincerely,

Jim Muckerheide