Re: Subcontractors

["Wesley M. Dunn" <WDUNN@brc1.tdh.state.tx.us>]

Don,

The question is "How are they legally using your sources?"  

If the individuals are not under control of the licensee, they must 
have their own license and the sources must be transferred to that 
license.  The only requisite records are the source transfer 
documents.

If the individuals are under the control of the licensee, they must 
follow the same requirements specified by the license.  This means 
the licensee must have documentation of all requisite training and 
dosimetry records.

NOTE: You should check with your regulator on how they define 
"control" in this usage.

Wes

> Date sent:      Mon, 18 Aug 97 09:28:03 -0500
> Send reply to:  radsafe@romulus.ehs.uiuc.edu
> From:           "Mercado, Don" <DMercado@svl.ems.lmco.com>
> To:             Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
> Subject:        Subcontractors

> My question this morning is about individuals not employed by/associated
> with your organization, who are using your radiation sources. What
> radiation protection requirements do you impose on this individual? Do
> you require their employer/organization to provide dosimetry/training or
> do you do that? Do you audit their employer's program? With increased
> requirements, doesn't your liability increase? Did you have to modify
> your license to allow outside contractors to use your radioactive
> sources?

*********************************************************************
Wesley M. Dunn, CHP                        512-834-6688
Deputy Director, Licensing                 512-834-6690 (fax)
(Texas) Bureau of Radiation Control        wdunn@brc1.tdh.state.tx.us
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