Re: Annual audits

[ehsnet!hps (HPS)]

Reply-to: Johnny.Brandon@p0.f13.n233.z1.fidonet.org (Johnny Brandon)
Fido-To: romulus.ehs.uiuc.edu!vmd.cso.uiuc.e

 r> I'd like to pick your brains concerning how your institutions plan to 
 r> fulfill the  requirement for an annual audit (20.1101(c)).  ...... 
 r> issue now that we've looked carefully at the most recent draft 
 r> revision to
 r> Reg. Guide 10.5 (Applying for a Broad Scope License) and its Section 
 
my first comment is that reg guides are just exactly what the name 
implies.... they're guides, they are not regulations.   10 CFR 20.2102 
calls for "audits and other reviews".  20.1101(c) requires you to 
"periodically [at least annually] review the radiation protection 
program content and implementation".   
 
IMHO, you have to conduct a credible review of your broad scope program 
(annually).  here at UIUC we conduct monthly audits to verify (for our 
own sense of ease :-) we have met all pertinent license commitments and 
we prepare an annual report that covers all aspects of our program.  
this report is submitted to our RSC for review/comment.
 
if you maintain good records, demonstrate your ability to exercise 
adminstrative oversight in correcting compliance problems you discover 
in your research laboratories, and audit the whole shebang you should be 
okay.... of course, you have to determine what is appropriate for your 
particular situation.
 
this probably doesn't help you in the least bit, but i hope it gives you 
a clear example of how one broad scope licensee handles this issue.
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