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 contaminated 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.