Re: MIT and NIH Incidents produce NRC Information Notice

[BFLOOD@SLAC.Stanford.EDU (Bob Flood)]

>I am skeptical that any licensee can " ensure that they have a 
>radiation safety program in place that will prevent deliberate 
>misuse of radioactive materials in all licensee areas."
>
>I believe that this is an impossible standard.
>

The regulatory environment is based on the philosophy that "perfection is
adequate." The law tolerates no imperfections at all. Since imperfections
are inevitable, it is equally inevitable that every program will fail to
meet the standard at least intermittently, and that every such failure will
be a "violation of federal regulation." The reality is "the best you can do
is the best you can do."

A program designed to ensure that deliberate misconduct is impossible is
regulatory myth. Others already know this, and that knowledge was the basis
for development of the concept of "Quality Assurance," which the regulators
have turned into "Perfection Guarantee."

Scrupulous HPs will work diligently to plug the gaps and take responsibility
for the (potential) actions of others, and make their programs as effective
as knowledge, skill, sleepless nights, and limited financial resources will
allow. The unscrupulous HP will ignore the problems, plan on not getting
caught, and sleep remarkably well.
Bob Flood
Unless otherwise noted, all opinions are mine alone.
(415) 926-3793
bflood@slac.stanford.edu