RSO qualification

[slaback@micf.nist.gov]

Question 2 of the NRC proposed rulemaking: 
Should the NRC incorporate requirements for the
duties and responsibilities of the RSO and RSC?

My draft response:
This question certainly offers the opportunity to gaurentee
employment for health physicists.  But the discussion offerred by
NRC for this proposal does not identify any deficiencies in the
current rules.  The mere lack of a regulation is viewed by most
as a plus.  Does NRC have data indicating a difficulty in this
area?  Our experience in our interactions with the RSO's of other
organizations is that they are at least adequately qualified (and
usually outstandingly qualified) for the position.  But the
nature of audience who will respond to this question (i.e.,
readers of the federal register) is that the NRC will get a very
biased response.  It would seem that this question would be
better addressed by a direct sampling process for the result to
have any meaning.

My question to the RADSAFE community:  How many slightly spoiled
apples are in the barrel?  Do you have any experience where you
interacted with an unqualified or poorly qualified RSO?
Note - we are talking about the organization RSO, not a staff HP.

As noted above I doubt that NRC will get a response on which they
can take a reasoned action.  Out of curiousity I will tabulate
responses sent directly to me (and I promise to delete forever
all frank replies) to the above question.

Having seen a lot of resume's while on the ABHP I can assure you
that it would be tough to write a qualification reg that did not
arbitrarely exclude someone without being so general that it
was useless.

P.S. You ARE working on your comments to this proposed rules,
aren't you?  [DoE and other foreign (non-U.S.) readers can ignore
this.]

A little risk adds spice to life.
Lester.Slaback@NIST.gov