To be or not to be

["J. J. Rozental" <josrozen@netmedia.net.il>]

 "Roy Ryder"   <R.Ryder@dl.ac.uk>

Thank you for your information, but I have some remarks:

Accident (according with the IAEA BSS I-115, 1994)
Any unintended event, including operating errors, failures or other mishaps,
the consequences or potential consequences of which are not negligible from
the point of view of protection or safety"

Is that a good conception? --

1 --  I personally have restrictions, because we need to specify the
understanding of not negligible;

2 -- The above conception also can be applied to incident

3 -- Comment:

a) Considering the conception as incident and assuming potential
consequences, the TMI, Chernobyl and Goiania are good examples, how
continuos errors give rise to incident be transformed in complexes accidents.

b) Nevertheless International Organization (or National as UK and EEUU) uses
several times the expression incident there is not (unbelievable) in any
International Organization the conception  (definition) of incident.
Experts only knows by hearth

c) Nevertheless, many experts  use the expression incident, they ask for
accident risk assessment...
 
d) Better conception is to consider Accident  (in the context of safety or
radiation protection) as an event that leads or could lead to abnormal
exposure conditions. 

e) Abnormal exposure conditions: Conditions in which a source or the
radiation from it is not under control

f) Incident: An event  of unintentional deviation from the practice that
leads or possible could lead to an unnecessary radiation exposure


II -- FINE (MONETARY PENALTY)

Enforcement no doubt, often involves some combination of technical and legal
skills....Nevertheless there are violations, even of no minor nature, that
the enforcement action involving fine (monetary penalty) should be applied
directly by the Competent Authority, considering the inspector report. An
Inspector,  I agree, cannot impose a fine directly. 
I will give you one example. Let's consider  the following accident
containing many violations, in which should be applied several sanctions,
including monetary penalty, directly by the Competent Authority, avoiding
Court, magistrate and jury, and of course bureaucracy and loss of time,
specially in the example, typically lack of Operational Safety Culture

The following overexposure accident was reported by NRC -- "In July/72 the
radiographer called the company to report the source disconnect. They told
him to shake it loose, pick it up by hand, and put it back in the camera.
The radiographer thought the procedure  would be dangerous and refused. By
phone the company told an untrained person to do the job. He did and was
overexposure." It is important to add: "No survey was made, no survey
meter was available at the site; source Ir-192 and activity 108 Ci; Dose 400
to 1000 rem to hand"
In terms of Court, only the untrained person should require his rights

III - Finally one word abaout the question:

 What background does the average inspector have?
  
 While discussing the specific task of the inspection  with the licensee
staff, (in this including the RPO and the manager responsible) the inspector
should has  the capacity of looking with the corner of the eyes

Thank you 

"J. J. Rozental" <josrozen@netmedia.net.il>
Consultant, Radiation Safety & Regulation
For Developing Country
Israel