Proposed revision of 10 CFR 33

[MVala@USCCMAIL.uscc.bms.com]

     Melissa-

     This is not a proposed rule yet - merely "specific examples of
     possible regulatory language".  With that said, I have a few immediate
     concerns on the regulatory language:

     1)  The definition of management "means the Chief Executive Officer or
     that person's delegate or delegates".  I work for a multinational
     multi-billion dollar corporation,  our pharmaceutical R&D program that
     uses rad materials is a minor part of the overall company. A Senior VP
     who oversees the division should be adequate.  This level of
     management would still be many layers below the CEO.

     2)  Multi-site Licenses - Interesting concept that seems to be working
     well for the Army and Air Force.  Would a national multi-site license
     cover sites that are in Agreement States?  or would a multi-site
     license be only applicable to NRC regulated states?

     3)  How will the NRC interpret "byproduct material ... will be used
     only by, or under the supervision of, (approved individuals)".  Must
     the senior investigator be in the lab or in the line of sight of all
     the people in their lab using rad materials?  If the approved user
     takes a day off does work in the lab cease?  Will we be forced to have
     RSC approval for every person that may work with licensed material?
     We can train everyone (and we do), but to bring up each person's
     qualification to the RSC and track their authorization would be an
     administrative nightmare.

     4)  Membership of the RSC - I agree with Melissa's comments, how will
     we accommodate a member of each "department, group, or activity that
     uses byproduct material" on a committee that is supposed to make real
     decisions?  Currently we have a ten member committee, three of whom
     are from R&D in some capacity.  It seems to work for us.

     Besides commenting on the proposed language, the NRC is soliciting our
     opinion on eleven specific questions concerning the regulatory
     oversight.  Is codifying these changes really necessary?  I don't
     know, but I will be sure to provide my comments to the NRC.  Everyone
     that may be affected should reply to the questions and comment on the
     proposed language.  If you don't, you will have no right to complain
     with the ultimate result of this NRC action.

     The comment deadline is 2/12/97.

     Mike Vala
     Bristol-Myers Squibb
     mvala@usccmail.bms.com
     908-519-2987

     **********************************************************************
     Date: Tue, 26 Nov 96 08:02:56 -0600
     From: "M. Woo" <melissa@zelda.ehs.uiuc.edu>
     Subject: RSO qualification/RSC content

     On a related but slightly different note, what about the content of
     the
     proposed rule?

     The proposed 33.21 states that "At a minimum, the Radiation Safety
     Officer shall have an academic degree in physical or biological
     science
     or engineering...," etc.  I know that this discussion has come up
     before in regards to application requirements for the ABHP exam, but
     I'm curious from what source this kind of intellectual elitism stems.
     I'm sure that are plenty of fine RSOs in practice right now who do not
     possess formal academic degrees.

     In reference to the make-up of the Radiation Safety Committee, the
     proposed 33.22 states that among other things, "Membership shall
     consist of... [some deleted] at least one user authorized by the
     Radiation Safety Committee from each of the departments, groups, or
     activities that will use byproduct materials permitted by the
     license... ."  Let's see... our campus football stadium isn't used for
     a good part of the year; maybe we can use that for our RSC meetings.