Re: Documentation of training - requirement for training records

[George Cicotte <GCICOTTE@GW.ODH.STATE.OH.US>]

With respect to Kent N. Lambert's post:

"Can anyone cite anywhere in 10 CFR 19 the requirement for training 
records?"

Although the following applies to workers likely to receive 100 mrem in a
year, the argument would be that failure to train ancillary workers makes
them more likely to receive in excess of 100 mrem.  You can't really get
around that.  You can limit their access, telling them only that there is
radioactivity involved, and that they can't go in except at certain times,
but if you don't imbue them with sufficient understanding, you'll have
people on their mid-shift lunch break making jiffy pop on the hot plate in
the I-125 air handling cabinet.  I saw that one with my own eyes.

10 CFR 19.12(b)
*. . . The extent of these instructions must be commensurate with
potential radiological health protection problems present in the work
place.*

10 CFR 20.1101
*(a) Each licensee shall . . . document . . . a radiation protection program
commensurate with the scope and extent of licensed activities and
sufficient to ensure compliance with the provisions of this part (see
20.2102 for recordkeeping requirements relating to these programs.)*

10 CFR 20.2102
*(a) Each licensee shall maintain records . . . including: (1) The provisions
of the program . . .*

If you want to know exactly how you'd be cited, check NRC's web site. 
They have the chapter and verse in there somewhere for the exact
citation they'd use.

V/R
George R. Cicotte
Health Physicist III
Ohio Department of Health
Bureau of Radiation Protection
Low-Level Radioactive Waste Section
gcicotte@gw.odh.state.oh.us

DISCLAIMER:  The Governor and I don't necessarily agree on official
statements - this is mine, and as such unofficial . . .