Re: personnel badging

[bflood@SLAC.Stanford.EDU (Bob Flood)]

>This question may have been asked before, but we are considering
>revising our badging of radionuclide users and would like to know the
>criteria other institutions use.  Our users handle mainly P-32 and would
>not be required to be badged according to 10CFR20 (i.e., they are not
>likely to receive 10% of the applicable limits).  Right now, we are
>requiring any individual using greater than 3 microcuries of P-32 to be
>monitored.  We are considering changing from monthly whole body and ring
>badges to one of the following:
>
>1.  Changing from monthly whole body and ring badges to quarterly whole
>body and ring badges.
>
>2.  Discontinuing whole body badges, but distribute quarterly ring
>badges.
>
>3.  Discontinuing all dosimeters for these individuals.
>
>We would also like to know how institutions badge (or don't badge) these
>individuals.  If you discontinued badging, how receptive were workers to
>this idea?  What criteria did you use to detrmine badging for these
>people?
>

The nuclear power inductry has gone through this issue in depth recently. In
their newly deregulated, cut-throat competition environment, many utilities
eliminated monitoring of many idividuals for whom monitoring was not
required by law (saving nickels and dimes). The NRC didn't just permit this;
they gave these programs high marks for forward-looking, efficient operation.

Then ANI stepped in. The American Nuclear Insurers provide the liability
insurance nuclear utilities are required to have under the Price-Anderson
Act. ANI saw the trend toward minimal dosimetry and told its customers,
"those of you who do not badge every person entering your controlled areas
will have your insurance rates adjusted upward substantially." ANI privately
estimated a factor of 3 increase. Nuclear utilities are going back to
badging everyone.

The reason is simple: the law says that the owner of the radiation is
responsible for any harm done by that radiation, and thus, licensees control
access to specific areas where radiation exposure is possible. When you
allow a person to enter a controlled area, you have an obligation to limit
exposure. You also have a need to demonstrate that exposure was limited,
i.e., by some form of dose measurements.

I have a few specific recommendations.

1. Look at your own data. If you can relate individual doses to the
quantities used, you may have a basis for raising the threshold above the
current 3 uCi level. Do this for whole body and extremity doses separately.

2. You don't mention lens of eye dose. If you are taking credit for
protective eyewear, be careful. If the eyewear is necessary to achieve the
low doses you expect, removing dosimetry leaves you no means other that
direct observation to detect when a person fails to wear the protective
eyewear as required. Note that this failure to wear the protective eyewear
would not relieve you of liability in court. Infortunately, "they didn't
make me do the right thing" is an acceptable agrument in court.

3. DON'T MAKE THIS DECISION YOURSELF, AND DON'T LET YOU HEALTH PHSICS OR
HEALTH & SAFETY MANAGEMENT MAKE THIS DECISION, EITHER. Health Physics is
obligated to make dose measurements so that personnel exposures can be
controlled. You also makes those measurements to protect your employer,
i.e., to produce evidence of having done the right things. Eliminating
dosimetry for a group of workers carries a risk for your employer that there
could be no evidence of having done the right things in a specific case.
This opens the situation to speculation about whether the right things were
actually done.

In any radiation injury claim, the plaintiff's dose will always be requested
and introduced in court. It may not be agrued in court, but the dose of
record will always turn up in the proceedings. If there is no recorded dose
because dosimetry was not provided, the plaintiff's speculation about the
dose is as valid as your employer's. It invites argument in court. How would
you like to agrue to the jury that we know his dose was small and probably
zero because we didn't give him a dosimeter?

Defensive dosimetry is not something to be proud of, but it's a reality in
today's workplace. Monitoring people for whom monitoring is not required by
10CFR20 is a legal issue, not a health protection one. It costs money, but
reduces risk of liability. Cutbacks can save money, but will increase risk.
Thus, the decision should be made by your employer's top management under
advice from your employer's attorney(s). Your job is to assemble the data -
how many badged now & the cost, how much can you cut back by changing the
criteria (have a basis in dose measurements, or plaintiff's attorney will
have an easy time of it) and the associated savings, and present these data
to your employer so that an informed decision can be made. They must decide
if the money saved is worth the increased risk.

Hope this helps. BTW, we went through this same exercise at SLAC, and
management decided to keep on badging everyone (all 12,000) who enters the
controlled area. I agree with the decision.

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