Re: I-131 procedure bioassay requirement

[Ccja@aol.com]

Richard

It has nothing to do with the 30 millicurie rule. The requirement is from Reg
Guide 8.20, and is that bioassay must be done if a worker uses 1 millicurie
in a calendar quarter, in a volatile or dispersable form, in an open room or
bench, with possible escape of iodine from the process vessels. In many
cases, capsules are considered to pass this test, so people don't do
bioassays. The problem with the case you present is that we don't know what
their licensure is. It could well require bioassays, at the described levels
of activity, regardless of encapsulation. They might also have inhouse
policies and procedures that require bioassays, under the described
conditions (note that these two situations are not mutually exclusive). In
either circumstance, if they didn't do the tests, they were in violation.

chris alston