10CFR19 training requirement

["Les Slaback, Health Physics" <SLABACK@micf.nist.gov>]

To extend Mike Grissom's last comment,
10CFR19 currently keys the training requirement to presence in a restricted
area, not being occupationally exposed.  The proposed revision to Parts 19
and 20 would change this.
I believe this is a mistake.
By definition the restricted area is where you have a radiation protection
program, including a training program.  Hence this  should be the key.
Under both the DoE and NRC definitions of occupational dose, people
outside the restricted area can be classed as receiving occupational dose,
but these might be people of whom the RPO has no knowledge.  If they are
being controlled like members-of-the-public why should the fact that they
are 'workers' precipitate a training requirement, and require the RPO to
'know' about them to apply that requirement?
This just opens a 'grey' area for the philosophical sake of asserting that
all workers should be 'trained'.

The training requirement properly should be keyed to where there is a
necessity to have a rad. protection program, which by definition is a
restricted area.

The NRC is still digesting this proposal, so you can still make your views
known, albeit well after the April '94 deadline.

If I am getting on my soapbox too much, let me know by direct mail to avoid
public flames roasting this forum excessively.

SLABACK@MICF.NIST.GOV
   ...a little risk, like a bit of spice, adds flavor to life