Re: RSO qualifications

[Lester.Slaback@nist.gov]

In <4AC7CB37450@brc1.tdh.state.tx.us>, on 05/05/97 
   at 02:16 PM, "Wesley M. Dunn" <WDUNN@brc1.tdh.state.tx.us> said:

>This may not directly address your question, but it may help provide 
>some background into the RSO discussion:

>The licensee submits a request to name an RSO, along with that 
>individual's education, training and experience.  There are often 
>guidelines as to acceptable qualifications versus the licensed 
>authorization.  If the qualifications are acceptable, the  individual is
>listed on the license.  

>Note that the RSO is designated at the licensee's "responsible"  person
>and is required to ensure all necessary requirements are met,  including
>ensuring everyone (including the RSO!) is appropriately  trained.  So it
>becomes a performance based standard for the RSO to  obtain any necessary
>continuing education to perform the job.  <snip>

Who has what responsibilities would seem to be dependent on the specific
license and organizational arrangement.  From a regulatory point it would
seem the person the regulator can really hold accountable is the person
who signs the license application as the representative of the
organization.  For a broad license where many players get into the game
(committee members, committee chairperson, RSO, management, etc.) it would
seem difficult to hold anyone other than the license application signee
(who we call the license manager) or the head of the organization (even if
not cited in the license) responsible.

The best concrete example of responsibility is who is liable for a
personal fine under 10CFR21.  This tends to get a persons attention rather
quickly.

And of course Wes is exactly right regarding who has the final say as to
RSO qualifications - the regulator.
__ 
the above are the personal musing of the author,
and do not represent any past, current, or future
position of NIST, the U.S. Government, or anyone else
who might think that they are in a position of authority.
NBSR Health Physics
NIST
Gaithersburg, MD 20899
301 975-5810
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Lester.Slaback@nist.gov
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