RE:

["Spell, Bill" <bills@deq.state.la.us>]

Our Radiation Protection Division has a "two-person" rule (regulation) for 
persons performing industrial radiography at temporary jobsites.  In fact, 
the rule currently states that both individuals will be certified 
radiographers, so that either is fully qualified to perform the duties of 
"radiographer," as specified in the Louisiana Radiation Regulations.  Our 
experience was that the un-qualified person was actually doing the work 
while the qualified person was in the darkroom developing and reading film. 
 Most of the excessive exposures were being racked-up by guess who?  Right, 
the one who was NOT cranking out the source.  We are retreating from this 
position a little to be more consistent with NRC and other states, but both 
persons are to be fully trained.  We feel it offers sufficient additional 
safety to require it, and we've had it in place since about 1988.

In an academic setting, since graduate students are considered "slave 
labor," it shouldn't be too hard to put into place, and I recommend it 
heartily.

Your view of working alone correspond in reverse to our definition of direct 
supervision.

Exempting GC/ECD detectors from a two-person rule will probably not be a 
problem as long as replacement and/or cleaning is NOT involved, and as long 
as it does not violate a condition of your radioactive material license or 
application.  When exchange is taking place, then you may want to have a 
supervisor present (again, if allowed).

Bill Spell, Administrator
La. Radiation Protection Division
bills@deq.state.la.us

These views are my own and will certainly not be shared by all, but you 
should get some worthy opinions.
 ----------
From: radsafe
To: Multiple recipients of list
Date: Friday, June 14, 1996 11:50AM

        As one of Georgia Tech general radioactive materials laboratory
safety rules, we have the "Two-Person Rule", i.e., when working with
radioactive materials, never work alone.  Working alone being defined as the
performance of any work by an individual who is out of audio or visual range
of another individual for more than a few minutes at a time OR without
access to a telephone WITHIN the laboratory.

        Our Nuclear Safeguards Committee has been asked to review the rule
with the possibility of exempting sealed sources like GC/ECD detectors
containing Ni-63 sources.

        Does anyone know of any regulatory basis for such a "Two-Person
Rule"? Comment's on the use of such a rule, especially as it relates to
sealed sources, exemption limits, or enforcement experience would be
appreciated.

        Rod Ice
        404/894-3621
        E-mail:  rod.ice@nnrc.gatech.edu


Rod Ice
Neely Nuclear Research Cener, Georgia Tech
Phone 404-894-3621
FAX   404-853-9325
EMail rod.ice@nnrc.gatech.edu