[Date Prev][Date Next][Thread Prev][Thread Next][Date Index][Thread Index]

RE: Documentation of Surveys by Lab Personnels



{Original Msg: 'Documenting Surveys by Lab Personnel' from <radsafe@romulus.ehs.uiuc.edu>
{
{Good Afternoon!  Our Radiation Safety Guide requires lab personnel to record
{the results of contamination surveys in a survey log - this includes the sur-
{vey they perform as they open radioisotope packages, as well as the work area
{and personal surveys which they perform.  It was suggested to us during an
{audit of our radiation safety program that we should consider eliminating the
{need to document surveys done by lab personnel.  The surveys would continue to
{be performed but no records of those surveys would exist.  Please note also
{our Health Physics Section does perform routine contamination surveys which are
{and would continue to be documented.
{
{This recommendation from our auditor had two aspects to it:  1)  We include our
{Radiation Safety Guide by reference in our license application, so when lab
{personnel don't document their surveys now, then we are out of compliance with
{license conditions (we plan to address this issue in part by eventually remov-
{ing the Guide as part of our license application), and 2) in actual practice,
{lab personnel often don't document their own surveys, so why impose a condition
{on them which doesn't produce great tangible benefits, which is not regulatori-
{ly required and for which compliance will be difficult to achieve?
{
{We are ourselves are not in agreement about this issue and we are very inter-
{ested in what approaches other institutions may take.  One idea we came up with
{was to require the logging of surveys only when contamination was discovered
{during the survey.  Please let me know how you have handled this question.
{Thanks so much for your help!
{
{Sue Dupre/Health Physicist/Princeton University
{dupre@princeton.edu
 
 
Sue,
What we do here is require documentation of the area surveys.  Package
receipt surveys are done by Research Office and documented.  Lab per-
sonnel are supposed to do personal surveys and check packages when they
open them but we do not require documentation.
 
Thinking about it I would prefer, I think that package and personnel
surveys be documented also rather than eliminate all survey documentation
by lab personnel.  The reason package and personal surveys aren't doc-
umented is that's the way it was when I got here and I haven't had any
problems.  People seem to be pretty aware when they receive a new pack-
age and are concerned about their own health.  I preach surveys and hand
washing and package surveys.  I must admit that because there is no doc-
umentation I do not really know that they are complying.  I can say that
I've only had one RAM box without the labels defaced show up in the 7
years I've been here.
 
I have had problems with area surveys.  Typically a lab will not use RAM
for a period of time and stop doing their area surveys.  At a later
date they start up with RAM use again and guess what, they forget to start
doing surveys again.  I've had that happen several times.  I now require
a weekly "No RAM use." entry on the survey sheet or log each seek if they
are not doing the surveys.  You can try and make it as easy as possible
with only a background level and levels above background referenced to
a lab diagram by grid or marked spot.  With wipe surveys you can do the
same or even less if they have an LSC or other print out to save.
 
When I worked at U.C. Berkeley, I know they had some P.I.s they would
not have wanted to trust to do surveys without documentation.  I don't
beleive they required documentation of either personal or package surveys.
Thay also did package recipt surveys and expected/required that P.I.s
check the boxes for residual contamination.
 
I can also see the NRC citing you [Princeton] if you required surveys but
not documentation if the  lab personnel could not provide documentation.
They seem to take the attitude that if it isn't on paper, it didn't happen.
So far the inspectors I'v had here have been rigorous about Nuclear Med-
icine surveys [Part 35 requires daily meter survey and weekly contam-
ination surveys] and pretty forgiving about the Research ones.  I have
never been asked about surveys of personnel or packages other than what
is required by part 20.
 
Regards,
Peter G. Vernig, VA Medical Center, Denver vernig.peter@forum.va.gov
 
 
************************************************************************
VA Medical Center, 1055 Clermont St. MS 115 - DISCLAIMER
Denver, CO 80220; 303-399-8020 x2447 FAX 393-4656 Opinions = Mine
FAX 303-393-4656, vernig.peter@forum.va.gov Opinions =/ VA or USA
************************************************************************