Re: NRRPT Petition for Rulemaking

[David Scherer <scherer@uiuc.edu>]

At 10:03 AM 2/23/96 -0600, you wrote:

>I have just read the February 8, 1996 Federal Register.  There is an NRRPT 
>petition for rule making there that deals with qualifications for R.S.O.'s 
>(10CFR35.900) at medical institutions that has me somewhat concerned.

In my opinion, the proposal has good and bad elements.  I support the
request to recognize NRRPT registry as evidence of adequate training in
radiation protection science.  However, I do not support the request to
reduce the hospital-based experience from 12 months to 3.  The concerns and
issues faced in a medical environment are different from those in an
industrial one.  A medical HP has responsibilities affecting patient
protection (e.g. QMP, HDR treatments, dose calibrator checks, etc.) as well
as the usual ones affecting workers and members of the public.  I do not
believe that 3 months is likely to provide adequate experience in these
concerns that are unique in the health physics community.

I should mention that I believe that these concerns also apply to CHPs as
well.  However, the AAHP's ethics statement appears to prohibit CHPs from
taking on sole responsibility for a medical program without adequate
previous experience.

Just my opinoin for what it's worth.

Dave Scherer
scherer@uiuc.edu