Annual Audits / Inquiry from Sue Dupre

[VERNIG.PETER@forum.va.gov]

Sue asked about audits under part 20. 1101(c).
VA Medical Centers operate under part 35 (Medical Use) as well
as part 20 and others.  Note most larger VAs are broad scope
licensees.  Part 35 has for some time had a requirement that the
Rad Safety Committee review anually the Rad Safety Program.
 
I and smoe others have had difficulty trying to get RSC members to
do a review.  They plead insufficient time and or expertice.  To
solve this a number of VA s in our Western Region, informally 
agreed to do reciprocal audits.  I have found that useful, and as
the gentleman from Texas indicated it helps both the auditor and
the facility being audited.  In our case the auditor acts as a
consultant to the RSC but the cost is only for travel which is
paid for by the receiving site.  Recently regional Health Physicist
have been hired and now they do some audits also but at least in
Western Region, there are too many facilities for the REgional HP
to do each facility every year.  Our program has, I think been well
accepted by the NRC.  Finally the suggestion that HPS or CRSO help
coordinate such audits is I think a good one.  We felt that if
you audit your auditor it could look like "I'll make you look
good and you make me look good."  So we've tried to shift things
a little.
 
I probably need a disclaimer for this.  It's my opinion and nobody
elses, certainly not VA Denver, VA, or US Government policy.