Re: Re[2]: NRRPT & 10 CFR 835

[Keith Welch <welch@CEBAF.GOV>]

At 03:03 PM 1/28/97 -0600, you wrote:

I agree with Steve's suggestion, with minor change.  Since "DOE core
academics" are themselves not alluded to in the revision (or current rule),
I would put the statement in context with what is already proposed:  Add to
835.901(e) - 
For elements of the training not specific to a particular DOE site, this
requirement shall be considered satisfied by NRRPT registration.

(this does not exempt an RCT from re-training)


Most importantly, for these suggestions to have any impact, we need to
provide these comments and suggestions for the DOE to consider in the revision.

I encourage anyone who has taken the time to provide an opinion here on this
subject to also do so at the web page where comments can be sent to DOE.
The address has been posted several times.


Keith Welch
Jefferson Lab
welch@cebaf.gov

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>     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
>