Re: Documentation of training for ancillary personnel

["Sandy Perle" <sandyfl@ix.netcom.com>]

I agree with both Kent and Mike with respect to the requirements of 
Part 19 and 20 with respect to documentation. My only comment is that 
one should evaluate whether they are willing only to achieve what 
meets the letter of the law, or, the intent. We could all do less and 
meet the regulatory requirements. The real question is, how much risk 
are you willing to assume? The regulations will not keep you out of 
litigation, nor will the NRC stand next to you on the witness stand, 
or a State regulator, for that matter. I think having the paperwork 
of what was presented and a signature is a must. The testing, well, 
that is the perrogative of the facility. Just depends on what 
materials you bring with you when you "potenbtially" end up in 
litigation. I hope this doesn't sound like "The sky is falling." I am 
only relating what I have found to be the trend in the nuclear 
industry .. litigation is there .. it's only a matter of time until 
you get caught in it's ugly web. Doesn't matter if you win, it will 
still cost a facility millions to even have a case thrown out. Costs 
more if you lose.

------------------
Sandy Perle
Technical Director
ICN Dosimetry Division
Costa Mesa, CA 92626
Office: (800) 548-5100 x2306 
Fax:    (714) 668-3149
  
mailto:sandyfl@ix.netcom.com
mailto:sperle@icnpharm.com

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