Re: NRRPT Proposed Rulemaking

[elw1@ix.netcom.com (Edwin Wright)]

> The petitioner recommends the following amendments to 10CFR part 35.
>
>1.  In 35.900, paragraphs (b) and (c) are redesignated as paragraphs 
>(c) and (d), respectively, and a new paragraph (b) is added to read as 
>follows:
>
>35.900 Radiation Safety Officer.
>
>*    *    *    *    *    *    *    *    *    *    *
>
>(b)  Is registered by the National Registry of Radiation Protection 
>Technologists and has had three months full-time experience as a 
>radiation safety technologist or radiation safety specialist at a 
>medical institution under the supervision of the individual identified 
>as the Radiation Safety Officer on a Commission or Agreement State 
>license that authorizes the use of byproduct material; or
>
>*    *    *    *    *    *    *    *    *    *    *

It is my opinion that the current wording is adequate enough to cover 
requirements for a technologist RSO. Current paragraph (b) requires 
training in radiation biology and radiopharmaceutical chemistry which 
are not covered in the NRRPT exam. I also agree with an earlier post, 
that 3 months is not enough time for experience.

The regulation should stand as currently written.

Edwin L. Wright, NRRPT, CHP
elw1@ix.netcom.com