REGULATIONS FROM SCRATCH

[Frank.E.Gallagher@apollo.adcom.uci.edu, III <fegallag@uci.edu>]

Radsafers,

     Here are a few comments on why we might write regulations in a much
different form today than those we currently have in our federal and state
codes. 

     A significant problem in many radiation protection programs in research
is that our radsafe procedures, and the regulatory program that led to them,
are based on the uses of radioactive materials that were common 20-30 years
ago.  The uses have "downsized", but the regulatory impact has not (I think
the term "inertia" applies here).

     In the old days, it was common to use 50-100 mCi of P-32 (with minimal
shielding) to label nucleotides in-house, with 90%-95% of the original
activity ending up as radioactive waste, while now we can buy 0.25-1 mCi of
labeled ATP, for example, at a very reasonable cost (and can easily obtain
lots of excellent beta shielding from our vendors).  For H-3, it was fairly
common to use 5-10 Ci of tritiated water to produce tens to hundreds of mCi
of a tritiated compound.  We still have a few people authorized to do these
procedures, but they have not done them in years and years.

     These uses led to real occupational exposures and lots of serious
spills.  Now, we have very occasional spills and only have significant
personnel exposures in a few areas of medicine, such as production of
radiopharmaceuticals for PET (note the similarity to the P-32 and H-3 uses
above), and x-rays, and when some unbalanced person commits a criminal act.

     Now, I get bored out of my mind reviewing vendor supplied dosimetry
reports with pages and pages and pages of "Not Detected" data.  The problem
(except for PET and some x-ray facilities) is no longer reducing doses to
make them ALARA, but convincing workers of the need to return film badges on
time even if the badges never show any exposures.  Instead of making real
contributions to the safety of research, we have become radiation safety nags. 



Frank E. Gallagher, III, CHP            
Manager, Radiation Protection           
  and Radiation Safety Officer
Environmental Health & Safety Office    Phone:  (714) 824-6904
University of California                Fax:    (714) 824-8539
Irvine, CA   92717-2725                 E-mail: fegallag@uci.edu