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Re: Occupational and Public Dose



>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..."

Note that the definition does not state "employment by the licensee," just
employment. DOE considers visiting scientists employed and doing work that
is part of that employment, even if the facility is not owned or operated by
the scientist's employer. It is exposure that occurs in the pursuit of one's
occupation and, therefore, occupational dose.


>>What about volunteers?  In hospitals there are many people who volunteer

This is a tough issue. I have no experience with exposure levels of
volunteers in hospital environments, but I would suggest that they be
treated as employees, i.e. monitored if a prospective determination finds
that exceeding the monitoring threshold is likely. It's conservative (which
isn't always good health physics), and demonstrates an active interest in
occupational safety. I suspect that the workload and cost of monitoring
suchg volunteers would be small.

     
>>What about a member of the clergy who visits brachytherapy patients?  

Aren't such visits a normal part of the clergy occupation? A paid or even
unpaid church official performing such tasks could easily be seen as
conducting routine activities of the profession. How's that for a can of
worms? In the NRC-regulated world, justifying no monitoring because exposure
is below 500 mrem/y shouldn't be too difficult, but you'd have to know every
member of the clergy entering your hospital for such purposes, stay times,
frequency of visits, etc. Unmanagable, I'd say, unless the determination can
be done for a class of workers, i.e., a specific occupation in a specific
situation.


>What about students?  In universities students routinely use radioactive 
>material in the course of their ***activities***.  Students are customers, 
>not employees.<

Students have an occupation - "student." Should fit the same profile as
visiting scientists. They aren't employed by the licensee, but any exposure
that occurs as part of the educational process also happens in the pursuit
of the student's occupation.

Bob Flood
Unless otherwise noted, all opinions are mine alone.
(415) 926-3793
bflood@slac.stanford.edu