Re: Occupational and Public Dose

[sandy_perle@email.fpl.com]

     Kent,
     
     Interesting questions raised. I'll state my opinion and see if we can 
     have one of the NRC regulars provide their interpretation.

>When the re-definition of Occupational Dose came out last September, I 
raised the following question with the NRC but I never received an 
answer.<
     
<The revised definition states, "Occupational dose means the dose received 
by an individual ***in the course of employment*** in which the 
individual's assigned duties involve exposure to radiation and/or to 
radioactive material..."  And, the NMSS Licensee Newsletter states,
"Licensees must control doses to individuals ***who are not employees*** with 
assigned duties involving radiation to within the public dose limit..." <
     
>What about volunteers?  In hospitals there are many people who volunteer 
their time but are not employees and may be exposed to radiation in the 
course of their ***activities***.  One could argue that a volunteer is an 
unpaid employee, but this is a stretch.  If they are employees wouldn't 
minimum wage laws apply?<

I would interpret that a volunteer is considered "as an employee" even if 
there is no compensation. Employment does not necessarily correlate to 
compensation rendered for the services. There are other forms of 
compensation, i.e., experience gained. Example, my son in his 1st year of 
law school received employment during the summer for the "experience" and 
received no financial compensation. He was technically an employee and was 
under their "direct control." Same as my HS senior who volunteers about 10 
hours a week at an animal hospital. Therefore, I'd say that the volunteer 
would come under the occupational worker .. but then again, one isn't 
considered an occupational worker unless they cross the 100 mrem in a year 
threshold.
     
>What about a member of the clergy who visits brachytherapy patients?  
What about students?  In universities students routinely use radioactive 
material in the course of their ***activities***.  Students are customers, 
not employees.<

I'd call this person a visitor and therefore a member of the public, 
unless the clergy falls under the "volunteer" category detailed above, and 
who performs this function on a regular basis "for" the facility.

As usual. Kent raises some interesting questions...

Sandy Perle
Supervisor Health Physics
Florida Power and Light Company

sandy_perle@email.fpl.com

Homepages: http://www.netcom.com/~sandyfl/home.html
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