Re: NRRPT Proposed Rulemaking

["R. G. Oesterling" <rgo@srv.net>]

At 14:13 2/23/96 -0600, Sinisterra,Andres wrote:
>
>Hi all:
>
>My previous query has to do with the requirements for an R.S.O. at medical 
>institutions.  Out of respect to the list members, at this time I reverve an 
>opinion because I want to see what the feeling is.
>
>The proposed amendment reads as follows:
>
>
>
> 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 o 
>byproduct material; or
>
>*    *    *    *    *    *    *    *    *    *    *
>
>
>I hope that my typing was accurate and I apologize for not sending this 
>earlier to avoid confusion.
>
>
>Andris
>
> --------------------------------------------------------------------
>Andris Sinisterra
>Asst. R.S.O. for Medicine
>University of Connecticut Health Center
>
>sinisterra@adp.uchc.edu
> --------------------------------------------------------------------


OK, so I'm an elitist.  However, the operative word here should be the "T"
which stands for *Technologist*, which rhymes with ....

While I have great respect for those who have passed the NRRPT exam, the
fact remains that it tests for knowledge at the "technologist" level.
Consequently, it seems to me that the experience requirements ought to be on
the order of three *years*, not three months.  Also, the experience should
be under the direction of a competent (which I won't attempt to define) RSO
with the intent that the apprentice will become the new RSO.

R. G. Oesterling, CHP