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Re: regulations, compliance, etc. (reply)



Taking Brian's comments a step further, the time to complain about regulations 
which don't promote safety is when they're out for comment.  How many of us 
were "asleep at the switch" when a poorly written regulation was finalized 
because we failed to point that out to the regulators?  It is rare that a 
valid comment is ignored. 
 
Bill Lipton 
The opinions expressed are strictly mine. 
Here's to a risk free world, and other fantasies. 





I don't see how (necessarily) regulations and safety are mutually 
exclusive.  True, some regulations are not created in the direct interest 
of safety, and some have only the most tenuous link to safety, but a 
blanket statement that they're diametrically opposed misses the forest for 
the trees.

In the article forwarded by Sandy, the fine was levied for failure to 
follow administrative requirements, a REQUIREMENT for licensing, right?  In 
most States, insurance is required to drive an automobile, an 
administrative requirement that does nothing to promote safety, but is 
considered to be in the best interest of the "public good".  

Poor radiation protection practices have caused our field enormous grief, 
both public and private.  The "fallout" (no pun intended) of incidents and 
accidents is increased regulation and scrutiny.  While the resulting 
regulation is (usually) overly zealous, the INTENT of the regulation is to 
correct a perceived shortcoming in the practices or situation(s) observed.  
 I cannot and will not support regulators that are more interested in the 
letter of the law than in the intent, though frequently the intent is in 
the letter.   It's in understanding the intent that some people fail when 
interpreting the regulations.  

While there are many of us that would operate in a fully safe and 
professional (not to mention happy!) manner without any regulation, how 
many can say (privately and honestly) that their employers (past and 
present) would be so enthusiastic about operating an excellent program?  
The reality must be faced that without regulation, there would be increased 
probability for egregious  violations of basic radiation protection 
precepts.

The above is my personal opinion, and in no way reflects the views of, or 
has any bearing on my employer.

Brian Rees
brees@lanl.gov