Re: What would we do with a threshold? -

["Sandy Perle" <sandyfl@ix.netcom.com>]

It is a shame that the DeMinimis concept was rejected, prior to 
publishing the revised Part 20. It was in it, even though the value 
arguably was lower than it should have been, but it was in the 
regulation. Having the concept published would have at least gotten 
the threshold "foot in the door". In reality, although there is no 
official DeMinimis value, there are many "Thresholds". The 10% of any 
annual limit is a threshold. Essentially the regulators are saying 
that if one receives <500 mrem/year (TEDE), the individual does not 
even need to be monitored. DeMinimis and BRC are nice concepts. We 
need more and, we need higher thresholds. The scientific community 
and the experts need to put their heads together so that "reasonable" 
regulations can be promulgated. Let's build on the "current" 
deMinimis values .. extend them .. to the point there is logic based 
on real risks, not just perceived risks. We can dictate doses down to 
the point where there will be minimal exposures to an individual, 
BUT, the work still needs to be done, and, that will only mean 
exposing a larger segment of the population to ensure that the work 
does get completed. Of course you have to consider the extra dose due 
to transition, different shifts, work in progress needs to be 
re-started after a briefing, etc. This doesn't make sense. We need 
logic and we need reasonable perseverance.

------------------
Sandy Perle
Technical Director
ICN Dosimetry Division
Costa Mesa, CA 92626
Office: (800) 548-5100 x2306 
Fax:    (714) 668-3149
  
mailto:sandyfl@ix.netcom.com
mailto:sperle@icnpharm.com

ICN Dosimetry Website:
http://www.dosimetry.com

Personal Homepage:
http://www.geocities.com/CapeCanaveral/1205 
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"The object of opening the mind, as of opening 
the mouth, is to close it again on something solid"
              - G. K. Chesterton -