Re[2]: posting requirements

[roseb@smtp-gw.gdls.com (Boyd H Rose)]

Two points are in order.
     
1.  There is no requirement to post restricted areas.  Just lock the 
door to prevent access to the radioactive material and the area is, 
by definition, a restricted area.

     I used restricted area in a broad sense for the purpose of my 
     post.  I was trying to avoid having to spell out all of the 
     conditions under which the radiation symbol is required by 
     10CFR20.1902 to be posted.
     
2.  The  CRAM posting is required for the presence of 10x Appendix C 
quantities.  So if I have a researcher using 5 mCi of P-33 (5x 
Appendix C) and I label the door, have I mislead workers and members 
of the public?

     In this case, you have not misled workers and members of the 
     public.  You have hopefully made a judgment based on the hazard 
     potential that it was necessary to extend the caution posting to 
     the door to warn workers and the public of the presence of the 
     P-33.  If parts 1903 and 1904 are followed, posting the room is 
     not required.  The  judgment to make the additional posting may 
     prevent unnecessary exposure to RAM for administrative purposes 
     (may limit unnecessary investigations, reporting, and otherwise 
     reacting to situations caused as a result of the limited 
     knowledge of the exposed person of the degrees of radiological 
     hazards).  This is far different from the judgment to post the 
     area CRAM to avoid having the room vandalized or having a 
     non-radioactive item stolen.

If a researcher conducts an experiment once a month should the room 
be posted during the experiment, and unposted after the waste is 
removed?  I don't believe (and I expect that no one out there 
believes) that we should waste our time posting and unposting 
facilities as the activity levels rise above and below the posting 
threshold. 

     Again, the above is a judgment call based on the working 
     situation at the licensed facility.  If once a month means 10 to 
     15 out of 20 consecutive workdays every month, then keeping the 
     room posted is justified.  Otherwise, to continuously post an 
     entire room is not required and could result in excessive 
     restriction on the use of the room for other than radiological 
     work when radiation sources are neither being used or present.  
     Besides, how much time does it take to post and unpost temporary 
     signs or apply physical controls such as barricades, lockable 
     storage cabinets, etc., and locking the room if necessary?
     
While I agree that using the radiation symbol for non radioactive 
work is "blatantly misleading" and should be discouraged, keep 
in mind that this could be considered an extension of accepted 
practices depending on one's perspective.

     One should never have the perspective that it is acceptable 
     practice to post that a potential hazards exist in order to 
     prevent situations which are in no way remotely related to 
     the hazards.


Kent N. Lambert, M.S., CHP
lambert@auhs.edu
Allegheny University of the Health Sciences 
Hahnemann Division
Radiation Physics and Safety, MS 106 
Broad and Vine Streets
Philadelphia, PA  19102-1192
     
215-762-8768 (voice)
215-762-7683 (fax)  

     Boyd H. Rose, CM, IHIT
     Radiation Protection Officer
     General Dynamics Land Systems Division
     roseb@gdls.com
     
     The opinions expressed above are solely my own and do not under any 
     circumstance reflect those of my employer.