Re:gulations

[Roger Gelder <74167.2472@CompuServe.COM>]

Sorry to have been late in coming back on Regulations but my E-mail 
has been troublesome.
First :- a very substantial disclaimer -- I am not an inspector hence my
views would be individual and unlikely to meet HSE (Health & Safety Insp)
standards. I have carried out surveys on their behalf under contract.
Second: accidents and incidents usually get confirmed in Courts of Law
locally, when an inspector prosecutes for a failure to comply with regulations.
The latter is invariably obvious and it usually happens that where there has 
been one failure there are often several more to go with the first. Before 
current legislation fines had become derisory but the latest level of fines
can be severe, particularly if the breeches of Regs are seen to serious.

However,  UK Regs are fairly open and in addition are supported first
by Codes of Practice - which explain many of the worst potential problems - 
and also by Guidance Notes which go into even greater depth. All three are 
issued by the Inspectorate after wide spread consultation.

The main thread throughout are the principles of ALARA (as low as readily
achievable) and ALARP (as low as reasonably practicable).
The first is much stronger than the second which allows debate, and might
highlight the LNT view held by some.
Inspectors receive substantial training and have to hold senior rank before 
being allocated 'Specialist Inspector' in a radiation category.

At risk of starting a serious fire (where are my asbestos pants?), a good 
example would be that from the San Onofre cats of last year. 
A UK inspector would undoubtedly ask where the unsecured access to
free contamination had arisen. It would not matter that the site was closed.
Next he would require survey reports - which presumably did not exist else
the cats would not have been allowed in. The complaint he might raise
would concern the possibility of unneccesary potential contamination to
which site staff could be exposed because of a 'lack of due care'.
      You can, I hope, see the thread of developement that a UK inspector 
could well adopt, although if justification existed, he might accept the 
situation after a clean-up - but I doubt it.

              I really do not wish to start a problem, but think this might
explain
UK approaches to legislation. Cerainly very few users get to a prosecution 
situation - possibly fewer than 10 to 20 in a year, for an estimated 30,000
industrial users and perhaps a similar number in nuclear work.

Roger Gelder,
Exposure Estimation Group,
National Radiological Protection Board,
Chilton, Oxon., UK

E-mail      home       74167.2472@compuserve.com
                  office        Roger.Gelder@NRPB.ORG.UK