Re: Multi-clinic Monitoring

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

It all comes down to regulatory jurisdiction.  Most radiation control
programs don't regulate the technologists, hence, they can't directly
do much (NOTE: The NRC does routinely levy penalties against
employees, though usually people in supervisory capacities --
such penalties are usually restrictions against working in the
field).  As such, most compliance action is limited to the regulated
entity (the registrant).  So it is beholden upon the registrant to
ensure that all employees provide complete dosimetry records.

Some states do regulate technologists, but it is usually not the
radiation control program (Illinois Dept Nucl Safety is one exception.
Texas Dept Health regulates techs and radiation, but they are two
separate agencies within the Department).  Hence, any action against
the tech would be a secondary effect (maybe a complaint filed by the
registrant or information passed on by the radiation control program).

Be that as it may, the registrant may have grounds for firing the
tech for hiding such information.  So the tech isn't home free just
because the radiation control program doesn't cite them personally.

Wes

> Date:          Fri, 5 Apr 96 15:40:14 -0600
> Reply-to:      radsafe@romulus.ehs.uiuc.edu
> From:          Janine Katanic <katanic@ENGR.ORST.EDU>
> To:            Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
> Subject:       Re: Multi-clinic Monitoring

>     Getting back to this... Some nuc med techs, radiographers, etc...
> will moonlight to supplement their income. (I have.) Some also do not
> inform their supervisors that they are doing so. In this case..
>     **- Is the tech required to inform their employer of other
> occupational exposures?**
>     - If the tech IS indeed required, are there any penalties if
> she/he does not give full disclosure to their employer?
>     - If NOT, then it is up to the tech to do their own monitoring.
> In this case, if the tech determined that they were getting overexposure,
> I guess it would be pretty sticky to inform their bosses.
>
>         Curious,
>         Janine Katanic, CNMT, ARRT (N)
>         Grad Student, Oregon State University
>         katanic@flop.engr.orst.edu
>
>
*********************************************************************
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
*********************************************************************