Radiation Worker

[Slaback@micf.nist.gov]

Now that a pet pieve has been raised,
here is what I have argued previously.
Note that the definition of Occupational dose has since
been changed (but not as I suggested, sigh), and that the
issue of the public being categorized as rad.workers is
no longer built into the rules, but the essential issues
are still there.

Editor
Journal of Health Physics Society

Dear Sir:

Who is a Radiation Worker?   Various groups at one time or another
have attempted to define this term, to the best of my knowledge,
unsuccessfully.  My reason for raising this question is related to
the existing definition in 10CFR20 for Occupational Dose, which
states:

     "occupational dose.  The dose received by an individual in a
restricted area or in the course of employment in which the
individual's assigned duties involve exposure to radiation and to
radioactive material from licensed and unlicensed sources of
radiation, whether in the possession of the owner/operator or
licensee or other person.  Occupational dose does not include dose
received from background radiation, as a patient from medical
practices, from voluntary participation in medical research
programs, or as a member of the public."

The distinction between a person who is occupationally exposed and
a person who is a radiation worker rests essentially with the
decision to apply occupational dose limits.  Since most uses of
Occupational Dose presume the application of occupational dose
limits the distinction in these terms is negligible, for the
purpose of this discussion.  Other definitions of Occupational Dose
or Exposure exist, based similarly on exposure by employed workers. 
However, these definitions, including the above, do not incorporate
the most basic premise of ICRP and NCRP recommendations, namely,
Justification.  They simply identify the state of being
occupationally exposed, and then permit the application of
occupational limits to those identified persons.

I would like to point out two primary areas where this deficiency
creates difficulties.  First, the 10CFR20 definition invokes
occupational dose limits for persons simply on the basis of
geography, e.g., presence in a restricted area.  Persons who
otherwise would be considered subject to public dose limits are
subject to occupational limits simply by being in a restricted
area.  Of course Optimization, i.e., ALARA, in effect limits their
exposures to less than public limits.  But the underlying
presumption is fallacious because the Justification Principle has
not been satisfied.  Of particular concern in this instance is
branding members of the public who visit a restricted area as
radiation workers when all common sense says that they are not. 
Many facilities conduct education programs which include visits to
restricted areas.  I doubt that anyone considers such persons
radiation workers and the visitors would certainly have unfavorable
views with this label.

Secondly, any employed person whose duties result in exposure (with
the appropriate exclusions) is considered occupationally exposed. 
Again, the Justification Principle is not incorporated in the
process.  Simply being employed by someone is not justification for
application of the higher risks associated with occupational
exposure. If one asks the (simplistic?) question, "Should all
radiation workers receive appropriate training?", most persons
would answer positively.  But under the above definition there are
unknown numbers of employed persons exposed in unrestricted areas
that are technically receiving Occupational Doses, but of whom most
licensees have no knowledge or control and who certainly are not
evaluated as radiation workers.  The fact that they are subject to
occupational limits is moot, since their exposures are under
conditions within the constraints of the limits for the general
public.  But if in fact they should be considered occupationally
exposed, then they should be subject to the appropriate
optimization program, i.e., radiation protection program.  But the
justification process is a necessary precondition to such a
determination.

I suggest that Occupational Dose be defined as  "That dose
resulting from any activity Justified to be subject to the specific
limits for Occupational Dose, and if so Justified subject to an
appropriate dose Optimization program."  This places on the
employer or licensee the responsibility to make a Justification
determination to identify persons who are occupationally exposed,
and then to conduct an appropriate radiation protection program for
such identified persons.  In the absence of such identification,
all persons would be subject to general public limits.  The
decision process is transferred from an inflexible definition to a
local determination process, within the framework of the
appropriate oversight agency.  This definition also allows easy
application in non-traditional situations, e.g., exposure to
technologically enhanced natural radiation sources.  

Left unlabeled are workers exposed under general public conditions.