Re: Subcontractors

[Steven.Rima@DOEGJPO.COM (Steven Rima)]

     Don,
     
     In the DOE world, it is very similar to the NRC world in regard to 
     this question. We must comply with 10 CFR 835 on our worksites. (10 
     CFR 835 is at least 90% identical to 10 CFR 20.) If an entity came on 
     a site we "own" and wants to use "our" sources, they must comply with 
     our radiation protection program, including training, source control, 
     RWPs, dosimetry, PPE, etc... Radiation protection for the use of 
     sources we own and are responsible for would not be delegated to a 
     subcontractor. I can't think of a case where this would not be true if 
     they use our sources. (I also can't really think of many instances 
     where we would have a subcontractor use our sources; why own a source 
     if you have nobody qualified to use it? But then, that's another 
     subject entirely.)
     
     If someone comes on site to do work using "their" source, as with a 
     radiography subcontractor, then we have the option of deferring to 
     their program. Before I did that, however, I would obtain a copy of 
     their state/NRC license, determine who the RSO (or equivalent) is, get 
     a list of their personnel qualified to use the source, and work out 
     such issues as RWP controls, dosimetry, etc. I would then formally put 
     the answers to these items in writing to the subcontractor so that 
     there would be no misunderstandings later if something happens.
     
     Steven D. Rima, CHP
     Manager, Health Physics & Industrial Hygiene
     MACTEC-ERS
     steven.rima@doegjpo.com


______________________________ Reply Separator _________________________________
Subject: Subcontractors
Author:  "Mercado; Don" <DMercado@svl.ems.lmco.com> at Internet
Date:    8/18/97 9:25 AM


Happy Monday, Radsafers!        
     
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?
     
Any insight into this situation would be helpful. Thank in advance!
     
Don Mercado
Radiation Safety Officer
Lockheed Martin Missiles & Space
     
Don.Mercado@lmco.com
     
Would a fly without wings be called a "walk"?