Re: Re : Safety Culture

["J. J. Rozental" <josrozen@netmedia.net.il>]

At 09:22 AM 7/21/97 -0500, you wrote:
>  Jim Presley commented :
>>      
>>      I am not totally versed in how the source at Goianna was abandoned
>>      but I would speculate that it was not ultimately due to an oversight
>>      by a radiotherapist, physicist or some such similar person.
>>      I would expect that the professional staff either left or were
>>      let go before the facility was actually closed/abandoned.
>>       Who knows, perhaps they stated to management as they were leaving 
>>      "don't forget about the source". At this point it became a management
>>      responsibility with the ultimate responsibility for public safety 
>>      falling on the regulatory body.
>>      As a regulator, it is my view that an appropriate regulatory framework 
>>      was not in place to ensure that such sources were not abandoned.
>>      
>>      If I missed the mark on this one please let me know.
=========================

>      The IAEA report clearly states
>      
>       "....the professional and moral responsibiliy for the 
>      security of a radiaoactive source must lie with the person 
>      or persons licenced as responsible for it." 
>
>
>      Bryan Dixon
>      radbd@leeds.ac. uk
=====================================

 Bryan, Your assertion was precise, thank you

==================================
Dear Jim 

Relative to Responsibilities, the International Basic Safety Standards for
Protection against Ionizing Radiation and for the Safety of Radiation
Sources  - IAEA I-115 states:

106, page 14 -  The principal parties having the main responsibilities for
the application of Standards shall be:
a) registrants or licensees; and
b) employers.

107. Other parties shall have subsidiary responsibilities for the
application of the Standards. These parties may include, as appropriate:
a) suppliers;
b) workers;
c) radiation protection officers;
d) medical practitioners;
e) health professionals;
f) qualified experts;
g) Ethical Review Committees; and
h) any other parties shall have the general and specific responsibilities
set out in the Standards.

109. The general responsibilities of principal parties (see 106), within the
requirements specified by the Regulatory Authority, are:
....................
(b) (iii) - to identify any failures and shortcomings in the protection and
safety measures and resources, and to take steps to correct them and prevent
recurrence.

234. (page 26) - Security of sources -- Sources shall be kept secure so as
to prevent theft or damage and to prevent any unauthorized legal person from
carrying out any of the actions specified in the General Obligations for
practices of the Standards (see par. 207 and 208), by ensuring that:

a) control of sources...

Conclusion: For the above reasons and others that could  be done: -

a) The competent Authority is responsible for establishing a framework of
control by defining standards and taking enforcement action as appropriate.
Therefore, it is necessary for the competent authority to monitor the
regulated licensees or activities as a whole, by means of a Monitoring
Compliance Programme;

b) The owners or users of radiation sources are responsible for their security.
==============

A)The Brazilian National Commission of Nuclear Energy -CNEN- was not
informed about the clinic's demolition or stopping the use of the Cs-137 Unit;
In that opportunity I Was Director and responsible for licensing all user of
radioactive materials in Brazil


B) Safety Culture may appear to be a simple and direct subject. However, it
will often arise to be an issue of high complexity. Limitations risk
perception by  organization, induce serious obstacles for a better programme
of Safety and Radiation Protection.
Take a look again at par. 107 above: Safety Culture should be encouraged
among the varies parties and levels in the organization.

Regards, J. J. Rozental <josrozen@netmedia.net.il>