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Re: posting requirements
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
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
Kent N. Lambert, M.S., CHP
Allegheny University of the Health Sciences
Radiation Physics and Safety, MS 106
Broad and Vine Streets
Philadelphia, PA 19102-1192
Boyd H. Rose, CM, IHIT
Radiation Protection Officer
General Dynamics Land Systems Division
The opinions expressed above are solely my own and do not under any
circumstance reflect those of my employer.