Re[2]: Documentation of training for ancillary personnel

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

     So by this reasoning, any activity that does not have a SPECIFIC 
     regulatory requirement for documentation does not need to be 
     documented??? How does one prove that an activity was done if there is 
     no record of it? If someone sues for damage from radiation exposure, 
     and claims that you did not tell them about radiation hazards, how do 
     you prove that you did?
     
     It would seem prudent to me to document somehow that you have given 
     the required instructions to workers, whether or not you believe that 
     the NRC specifically requires the records or not.
     
     Steven D. Rima, CHP
     Manager, Health Physics and Industrial Hygiene
     MACTEC-ERS
     steven.rima@doegjpo.com


______________________________ Reply Separator _________________________________
Subject: Re: Documentation of training for ancillary personnel
Author:  "Kent N. Lambert" <lambert@allegheny.edu> at Internet
Date:    6/10/97 3:39 PM


MRBROWN @ Bechtel.com wrote:
     
> ... as an someone who has
> set both sides of the fence (regulator and licensee) - the ancillary 
> personnel are usually part of the group of training records they
> want to see...and if you can provide training rosters and a test, 
> the auditors go away happy...
     
Can anyone cite anywhere in 10 CFR 19 the requirement for training 
records?  Read 10 CFR 19.12 carefully.  There are none.  Nor are 
there any requirements in parts 20, 30, or 33.  BTW, the word 
"training" never appears in this paragraph.
     
The NRC recently rewrote the requirements in 10 CFR 19.12  for 
instructions to workers and they did NOT include a recordkeeping 
requirement.  Further, the NRC is not reticent in their regulations 
about requiring records for various radiation safety activities, 
including surveys, radiation safety committee meetings, dosimetry, 
etc.  Therefore, one can logically conclude that even recently, the 
Commissioners felt that keeping records of instructions to radiation 
workers was not necessary for the protection of workers from 
radiation, or (for the cynics out there) they felt it would not pass 
OMB review.  
     
This is not to say that records of instructions are not an important 
part of any radiation protection program.  Rather that  the records 
should satisfy YOUR needs.  If YOU feel that it is important to 
ensure comprehension because of the potential consequences of a 
failure to comprehend and comply with your instructions are worth 
the cost of administering an examination, then you should test the 
workers.  If YOU feel it is necessary to ensure that everyone 
attended, then a sign-in sheet is adequate.  (I don't hold much faith 
is signed statements that one understands the material presented.)
     
A caveat:  If you are in an agreement state, work for a DOE regulated 
organization, have agreed to training records as a part of your 
license agreement, or are an NRC part 35 licensee, then one must 
follow any appropriate requirements.
--
Kent N. Lambert, M.S., CHP
mailto:lambert@allegheny.edu