Re[2]: NRRPT & 10 CFR 835

[Steven.Rima@DOEGJPO.COM (Steven Rima)]

     While I agree very strongly in encouraging NRRPT registration, I do 
     not believe that regulatory language encouraging such is what we need. 
     As others have pointed out, it is impossible to regulate 
     "encouragement." I would instead propose the following:
     
     If language is codified regarding the NRRPT, I would encourage the 
     language to state that "NRRPT registration shall be accepted as 
     completion of the DOE RCT Core Academics training program." (or 
     similar)
     
     Justification: A very recent TRADE document entitled "Cross Reference 
     of NRRPT Knowledge Factors and RCT Core Academic Training Learning 
     Objectives" from the TRADE Radiation Protection Training Special 
     Interest Group addresses this subject. (This document is dated 
     September 1996.) It concludes that "The specific knowledges tested by 
     the NRRPT correlate well with the DOE RCT Core Academics Program 
     learning objectives." 
     
     This would be much stronger than "encouraging" registration, and would 
     itself encourage registration since it would preclude sending someone 
     through the core academics program.
     
     Steven D. Rima, CHP
     Manager, HP & IH Programs
     MACTEC-ERS
     steven.rima@doegjpo.com
     
     


______________________________ Reply Separator _________________________________
_________________________________
Subject: <NULL>
Author:  radsafe@romulus.ehs.uiuc.edu_at_INTERNET at X400PO 
Date:    1/27/97 7:36 AM
     
     
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