Appropriateness of RADSAFE Posting of Y90 Spill

[presley.j@atomcon.gc.ca]

     Radsafers,
     
     I have received some criticism of my RADSAFE
     posting regarding the Y90 spill.
     
     I would like to state my purpose/motivation
     for the posting and welcome any comments
     for my actions.
     
     First, I must explain that the regulatory environment
     in Canada is somewhat less 'prescriptive' than that
     in the US.
     Our regulations are somewhat general and open to
     interpretation. This has certain advantages and
     disadvantages over a strict prescriptive appraoch.
     
     For example :
     Section 24 states
     "Every person operating a nuclear facility ....
     shall.....
     ...take all reasonable precautions in relation to the nuclear facility 
     or the prescribed substance to protect persons and property from
     injury or damage ;"
     
     Now. so far this clause has not been interpreted by a judge for us
     so at times, people like myself are asked to interpret this clause and
     others like it.
     
     While I (and I guess my employer) consider myself competent to carry 
     out such interpretations, I do not consider myself infallible by
     any means.
     
     With regard to the  Y90 spill, I have my own strong opinion
     on this matter, which I have not stated so as not to influence the
     requested responses. However, others have stated quite different
     opinions on this incident and this brings me to RADSAFE.
     
     By posting the message on RADSAFE I wanted to tap the immense, 
     combined knowledge and experience available in this forum to see
     if perhaps my opinions might be out of line with other radiation
     safety professionals.
     
     If you respond publicly to this, I respectfully ask that you
     aim your comments at the use of RADSAFE, not to a discussion of
     the incident itself. Discussions of the incident should be
     directed to me personally.
     
     Jim Presley
     Senior Health Physicist
     Atomic Energy Control Board
     presley.j@atomcon.gc.ca