Re: Radiation monitoring badges in cine/floro exams

["Wesley M. Dunn" <WDUNN@brc1.tdh.state.tx.us>]

David,

Your arguments are correct.  However, one should recognize that many 
of the regulations promulgated by the various states are still based 
on NRC regulations.  For example, much of the Suggested State 
Regulations (SSRs) published by the Conference of Radiation Control 
Program Directors (CRCPD) comes from regulators working in Agreement 
States.  As such, they much prefer to use similar standards for the 
general case when possible (and adjusting them when needed).  So 10 
CFR 20 and NRC position papers are often a good starting point to how 
the states may regulate "other" forms of ionizing radiation.

Wes

> Date sent:      Thu, 7 Nov 96 10:53:02 -0600
> Send reply to:  radsafe@romulus.ehs.uiuc.edu
> From:           David W Lee <lee_david_w@lanl.gov>
> To:             Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
> Subject:        Re: Radiation monitoring badges in cine/floro exams

> But it is also important to point out that NRC rules do not apply to
> virtually all U.S. cine/fluoro environments which normally use x-ray
> machines which the NRC is not authorized to regulate!  Thus, within the
> non-NRC x-ray world, the issue still remains.  It is the NRC's lack of
> regulatory authority in this arena that has forced the Agreement States to
> try to compensate and fill this regulatory gap.  The State of Texas, as one
> Agreement State example, has made a good effort in this respect.  It is
> probably inappropriate to try to follow NRC dosimeter placement guidance in
> areas where the NRC, itself, has no regulatory authority.  For example, in
> the NRC-world, most users of radioactive material do not wear lead aprons.

*********************************************************************
Wesley M. Dunn, CHP                        512-834-6688
Deputy Director, Licensing                 512-834-6690 (fax)
(Texas) Bureau of Radiation Control        wdunn@brc1.tdh.state.tx.us
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