Training of individuals in "restricted" areas

[Mack Richard <MRICHARD@WPO.IUPUI.EDU>]

Dale Boyce implied that it would be necessary to train anyone who
entered a research lab which is considered a "restricted area."  Is this
really true?  Given the recent change in 10 CFR 19.12, I'm not so sure. 
19.12 requires training for anyone who is " . . . likely to receive in a
year an occupational dose in excess of 100 mrem . . ."  

I think we could argue that janitors, maintenance staff, or other
non-radionuclide users in the lab are not likely to receive 100 mrem in
one year.  However, there is a "catch 22" part of this section of the
regs (10 CFR 19.12(b)) which requires one to consider abnormal
situations (e.g. spills).  Could be open to "creative" interpretation by
both the NRC and licensees (e.g. if a janitor knocked off a radioactive
container and decided the spilled material would make a good condiment
for his sandwich).

We haven't decided as yet how to deal with this change; however, we
intend to give it some thought before we renew our license.  One still
must consider control of material (e.g. one must be sure janitors don't
dispose of the radwaste in normal trash, etc.).  Certainly food for
thought.

Mack Richard, M.S., RSO
Indiana University Medical Center
mrichard@wpo.iupui.edu

My employers rarely understand me - they certainly won't be held
accountable for my opinions.  Standard disclaimers apply.