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Re: To be or not to be



Dear Rozental, shalom!

Welcome to the Radsafers fraternity! I enjoyed very much your analysis.

I'm sorry that people like you, with so much experience in radiation 

protection management, have just now joined us.


Sergio 



 
 =============================================================================
 Sergio Faermann Ph.D.                      Tel: 972 - 7 -6 400682/6403301
 Chief Medical Physicist                    Fax: 972 - 7 -6 232336      
 Institute of Oncology                      E-mail: sergio@bgumail.bgu.ac.il
 Soroka Medical Center
 P.O.B 151 Beer-Sheva 84101
 ISRAEL
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On Tue, 7 Jan 1997, J. J. Rozental wrote:

> 
>  "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
>