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Re: Re: RSO qualifications

A recent change to NRC regulations is that, now, even unlicensed individuals 
who are employees or contractors of a licensee can be held individually 
accountable by the NRC in cases of deliberate misconduct.  See, for example, 
10 CFR 30.10, for biproduct licensees.  I remember hearing of a case, although 
I can't recall the details, where an employee was dismissed by his employer 
and also issued an individual Notice of Violation by the NRC.  Deliberate 
misconduct includes submitting information to the NRC that the individual 
knows is false. 
 
The opinions expressed are strictly mine. 
Here's to a risk free world, and other fantasies. 
 
Bill Lipton 
liptonw@detroitedison.com 





Les is correct.  I did not mean to imply the RSO would be held 
personally liable by the regulatory agencies (except in certain 
egregious examples of misconduct).  

The RSO is responsible for the day-to-day radiation safety program 
(e.g., implementation).  The regulated (and liable) entity is the 
llicensee, which is usually a corporation, partnership, company, 
etc..., and not an individual.

Wes

> Date sent:      Mon, 5 May 97 14:57:51 -0500
> Send reply to:  radsafe@romulus.ehs.uiuc.edu
> From:           Lester.Slaback@nist.gov
> To:             Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
> Subject:        Re: RSO qualifications

> 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.

*********************************************************************
Wesley M. Dunn, CHP                        512-834-6688
Deputy Director, Licensing                 512-834-6690 (fax)
(Texas) Bureau of Radiation Control        wdunn@brc1.tdh.state.tx.us
*********************************************************************