RE: 10 CFR 835 and NRRPT

[James G. Barnes <mail15077@pop.net>]

Good morning all,

While I agree with the *intent* of this request, I don't think it is 
appropriate to regulatory language.  How am I to demonstrate to a regulator 
that I have "encouraged" my personnel to participate in the NRRPT?  The 
language is just a bit too open to interpretation for my taste.

Possibly a better approach would be to say "registration by the NRRPT shall be 
considered as demonstration of adequate knowledge of the principles of 
radiation protection."  It doesn't preclude non-NRRPT personnel from other 
demonstrations, and it gives the NRRPT registered technician acknowledgement.

Jim Barnes; CHP, RPT
Radiation Safety Officer
Rocketdyne Division; Boeing North American


    > 
    > 
    > 
    > I encourage all NRRPT Members and other interested parties to submit the
    > following comment, or equivalent, in response to the proposed revision of
    > 10CFR835, "Occupational Radiation Protection." This revision appeared in
    > the Federal Register on December 23, 1996 (Vol.61, No.247).  Even if you
    > are not working in the DOE sector or Registered with the NRRPT, you are
    > entitled and to comment. Inclusion of the NRRPT credential in 10CFR835
    > indicates a standard of excellence in the area of technician 
    > qualifications
    > and enhances the value of Registration.  Similar wording is already
    > contained in the DOE RadCon Manual.
    > 
    > "In Subpart J., "Radiation Safety Training," Section (e), I request that
    > the following wording is added: Registration with the National Registry of
    > Radiation Protection Technologists is encouraged."
    > 
    > Send the comment to: Dr. Joel Rabovsky, U.S. Department of Energy, Office
    > of Worker Protection Programs and Hazardous Management.  EH-52, 1000
    > Independence Ave. SW, Washington DC 20585
    > 
    > Comment must be received by Feb. 21, 1997.  A floppy disc with the text in
    > an ASCII file or in WordPerfect 5.0 or later would be appreciated.
    > 
    > Sincerely,
    > 
    > Mike Boyle, RRPT, CHP
    > Chairman, National Registry of Radiation Protection Technologists
    > 
    > 
    > 
    >