Re: NRRPT Petition, NAS Report

["Wesley M. Dunn" <WDUNN@brc1.tdh.state.tx.us>]

Welp, I've reviewed the NAS/IOM report and have found it lacking much
in the way of analysis that could support any recommendation, let
alone the unworkable one proposed.  It is a marvel to read, but
presents a severe lack of understanding about radiation, radioactive
material, and the regulation thereof.  As such, it sounds
great and may well cause more damage than good.

The NRC and the Organization of Agreement States (OAS) are meeting
next week in a series of technical meetings, including one on Medical
Use.  My guess is that the state regulators are going to have few
compliments to toss NAS's way.  However, there may be an opportunity
to re-evaluate (heck, I'm not sure there ever HAS been an
evaluation) what is radiation control and what is practice of
medicine.  If that is done, it may be possible to actually resolve the
entire issue in a manner acceptable to regulators, users and the
public interest.

I strongly recommend that every HP take the chance and review and
comment on this report (I think April 11 is the comment deadline).  I
would be very interested in knowing how many HPs support federal
deregulation of radioactive material when used in medical settings,
but NOT for any other use.

Wes

> Date:          Tue, 27 Feb 96 09:41:14 -0600
> Reply-to:      radsafe@romulus.ehs.uiuc.edu
> From:          David Scherer <scherer@uiuc.edu>
> To:            Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
> Subject:       NRRPT Petition, NAS Report

> There has been recent discussion about the NRRPT's petition to amend 10 CFR
> 35.  This whole discussion may be moot anyway.  The National Academy of
> Sciences Institute of Medicine issued a report in December 1995 calling for
> abolishing NRC's authority over medical uses of byproduct materials.
> Authority would be transferred to the states to be administered along with
> their x-ray and NARM programs.

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Wesley M. Dunn, C.H.P.                     512-834-6688
Deputy Director, Licensing                 512-834-6690 (fax)
(Texas) Bureau of Radiation Control        wdunn@brc1.tdh.state.tx.us
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