Re: Small University Programs

[jgbarnes@ix.netcom.com (JAMES BARNES)]

Dear Tom,

I may be "shotgunning" this a bit broadly, but I'm not familiar with Nevada's 
regulatory twists and turns.  You might want to check out 10 CFR 33, as there are 
several classes of Broad Scope Licenses (under federal regulations), and Nevada 
may recognize them in order to mimic the federal statues.

As I don't know you specifics, it's hard to advise exactly, but it would seem 
that your "innovative" approach is actually a reasonable implementation of a 
Broad Scope License.  I would think this approach would work in California, as 
long as you had it fully documented, could demonstrate experience and training, 
the level of administrative presence matched the potential hazards etc. etc.

While not a university, we operate under a Broad Scope "A" license here at 
Rocketdyne with approximately 35 principal users (it varies from time to time).  
Each program is granted a use authorization, which is essentially a rad safety 
procedure issued by RP&HPS.  The principal user is then tasked with implementing 
the program and assuring compliance.  RP&HPS then provides an oversight and 
advice service.  The system is very flexible and can be easily tailored to the 
risk.  [From what I've been able to tell from other university RSOs in the area, 
this is a fairly common approach.]


Jim Barnes, CHP
Radiation Safety Officer
Rockwell Aerospace, Rocketdyne Division

-------------------------------------

You wrote: 
>
>     I would like to hear from RSO's of other academic radiation safety 
>     programs who are applying for broad-scope licenses or have had recent 
>     experience with such applications.  Our program faces a crisis in that 
>     there is only one professional position, that of RSO, and the history 
>     of our specified license has shown the need for an assistant RSO and a 
>     technical position.  On the other hand, we anticipate only ten to 
>     twelve users under the broad license, and no additional staff 
>     unless/untill the use increases.  Instead of a broad-scope license, we 
>     may be reduced to individual licenses for each user.
>     
>     The only alternative appears to be an "innovative" approach which will 
>     somehow combine a structure based on individual programs for each lab 
>     with a central RS Office and/or committee providing timely approval of 
>     research and teaching programs.  The individual programs would bear 
>     the burden of maintaining control of radioactive materials, enabling 
>     the RSO to keep knowledgeable of all activities and to review 
>     proposals, through minimizing technical and routine tasks.
>     
>     I am particularly interested in ideas and experiences regarding 
>     maintaining a small program through inevitable absences of the RSO for 
>     meetings, vacation, illness, and so forth.
>     
>     Thomas Graham
>     
>     graham@ccmail.nevada.edu
>
>