Re: REGULATIONS FROM SCRATCH

[MVala@USCCMAIL.uscc.bms.com]

     Frank,

     Who's inertia are we talking about here?

     New Part 20 clearly states that we only have to monitor those
     occupational workers whose dose may exceed 10% of the annual limits.
     If you have pages and pages of dosimety data that indicate "Non
     Detected" it sounds like it would be easy to justify eliminating or
     greatly reducing this part of your program.  The justification for
     this is in all those pages of negative data.  If your researchers are
     handling a couple of hundred microcuries a week of P-32, I-125, or
     similar material, your dosimetry program is probably an archive from
     the early days of R&D.  Your used to the program and so are the
     researchers, everyone may be bored by the page after page of negative
     data but they are comforted by seeing it.  A reduction of your
     dosimetry program would require some work up front and probably
     additional training to make everyone comfortable.  But look at what
     you gain - less paperwork, less badges to track, decreased costs, and
     continued compliance.  Your workmans comp lawyers probably like all
     the negative badge data, but I don't believe you are correct in
     blaming the regulations for this particular complaint.  The
     regulations have changed - maybe not enough for everyone's
     satisfaction. In these days of tight budgets and even tighter
     headcount we must balance all aspects of our radiation safety program
     to ensure compliance.  If we elect to exceed compliance, then we have
     to be able to ensure that there is some value added to the program.


     Thanks for the opportunity to sound off,

     Michael Vala
     mvala@usccmail.bms.com

______________________________ Reply Separator _________________________________
Subject: REGULATIONS FROM SCRATCH
Author:  radsafe@romulus.ehs.uiuc.edu at Internet/X400
Date:    6/26/96 10:32 AM


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).

     ............

     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