Reply to re:Multi-clinic Monitoring

[VERNIG.PETER@FORUM.VA.GOV]

{Original Msg: 're:Multi-clinic Monitoring' from <radsafe@romulus.ehs.uiuc.edu>
{
{
{The response to Question 216 in NUREG/CR-6204 "Questions and Answers Based on 
{Revised 10 CFR Part 20" touches on the issue of dose monitoring for medical 
{personnel who work at several facilities simultaneously. It indicates that  
{Appendix X to Regulatory Guide 10.8, Rev. 2 was developed to provide guidance 
{for the implementation of the revised Part 20 at a medical facility. The 
{response also says that this guide will be revised in its entirety in the 
{future to address the changes in 10 CFR Part 20.
{
{I don't know whether or not this revision has been completed.
{                                      
{Ben Morgan
{
{ben.morgan@cplc.com
{
{My employee has neither reviewed nor approved this message.
 
 
Ben,
I think the original question regarded radiologists.  As Wes Dunn
pointed out most agreement states have adopted their version of the new
part 20 and the practice is close to universal in state regs of treat-
ing radiation from all sources the same.  However in nonagreement states
and federal facilities, NRC has no authority over strictly machine produce
exposure.  That means the regulation defaults to OSHA under 29 CFR 1910.96
which in turn was cribbed from 70s vintage NRC regulations.
 The bad news is that OSHA did not to my knowledge publish or endorse
  any existing guidance documents such as NRC reg guides
 The good news is, I don't think most OSHA people, state or federal
  realize that they have this jurisdiction.
 
The situation could be really murky if a radiologist worked in both
agreement states and nonagreement states.
 
There must be some appropriate quote about regulatory nonsense.  Maybe
"It's a good thing we don't get all the government we pay for."
 
Regards,
Peter G. Vernig, vernig.peter@forum.va.gov
 
 
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