Silly requirements

["J. J. Rozental" <josrozen@netmedia.net.il>]

Peter J. Fundarek
University of Toronto
CANADA
email:  p.fundarek@utoronto.ca

Dear Peter, 

You wrote:

"This facility has been inspected twice a year by the AECB group responsible
for radioactive waste management for the past six years.  No problems have
been noted.  Now another inspector has come along.  He feels that, according
to the regulations, the inner source holders are considered containers and
therefore must be labelled with the proper signage!  He is writing a
non-compliance report since he considers these sources to be improperly marked."

Going to the "bible" IAEA BSS I-115 ones' learn about safety culture, page 354:

"The assembly of characteristics and attitudes in organizations and
individuals that establishes that, as an overriding priority, protection and
safety issues receive the attention warranted by their significance"

The same document and subject, 228 (b)page 24 state: "problems affecting
protection and safety be promptly identified and corrected in a manner
commensurate with their importance"

In the same document, as your responsibility, you can find:
108 b(iii) "to identify any failures and shortcomings in the protection and
safety measures, and to take steps to correct them and prevent their recurrence"


According with your conviction and the former AECB inspectors the importance
was  irrelevant. For my point of you view your organization should  don't
accept such violation and discuss it in the AECB. If  this constitutes a non
compliance the own AECB had consummate also worst violation, as competent
authority,  since for the past six years didn't identify the fact as a non
compliance. If you accept as non compliance this will figure in the register
of your organization. Radiation Safety Officer should be competent enough to
argue responsibilities with inspectors, in any place and situation. In this
case the maximum that you can accept is a recommendation and correct
accordingly.
Discuss the fact with the Canada Association of Radiological Protection and
Canada Association of Medical Physics


J. J. Rozental <josrozen@netmedia.net.il>
Consultant, Radiation Safety & Regulation
for developing country, Israel