Re: RE: Children in Research Areas

[David W Lee <lee_david_w@lanl.gov>]

	To muddy the waters even further on this issue, it is interesting to note
that at least within the DOE, occupational exposure limits are determined
merely by the worker's employment status and NOT upon whether the worker's
assigned duties intrinsically involve or necessitate occupational exposure
to source of ionizing radiation.  Within the DOE, the occupational exposure
limits of 5 rem/yr whole-body; 50 rem/yr skin, etc., are conferred upon any
"general employee" as soon as the employee completes General Employee
Training (GET) at the outset of DOE employment (see 10 CFR 835.202).  Thus,
a librarian, a janitor, and a person like Bob Flood, who presumably is
truly occupationally exposed to ionizing radiation in the course of his
normal job duties, within the DOE, ALL have the SAME exposure limits, i.e.,
5 rem/yr WB, 50 rem/yr skin, etc.  And a person under 18 years old, i.e., a
minor, who graduates from GET has the same exposure/dose limits.  The only
instance within the DOE in which any General Employee attains exposure/dose
limits different from the traditional limits normally thought to apply to
"radiation workers" is when a general employee formally declares her
pregnancy.

	If one were to then apply this DOE paradigm to the Irvine California
University situation, every employee of the University including students,
the instant each became graduated from some sort initial entry
employee/student training, would have the 5 rem/yr dose/exposure limits,
etc.  People who are actually "minors," i.e., not University
employees/students, such as children of faculty members on a "bring your
children to work day," would have the 100 mrem/yr dose limit.

Best regards  David



At 05:30 PM 5/8/1998 -0500, you wrote:
>At 03:31 PM 5/8/98 -0500, you wrote:
>>are not grad students "by definition" (if not in fact) an employee of 
>>the university?
>
>Whether an exposure is occupational is not necessarily related to whether
>the institution owning the radiation employs the exposed person. The
>exposure is occupational if the exposed person is pursuing his/her
>occupation, no matter who (if anyone) employs that person. The lawyers for
>the likes of NRC, DOE, OSHA, etc. take the approach that lab activities are
>part of a student's occupation, and that means any exposure is occupational
>exposure. And I agree.
>
>There may be a legal precedent on this matter that your legal staff could
>dig up.
>
>---------
>Bob Flood
>Dosimetry Group Leader
>Stanford Linear Accelerator Center
>(650) 926-3793
>bflood@slac.stanford.edu
>
>
>

DAVID W. LEE
Los Alamos National Laboratory
PO Box 1663, MS K483
Los Alamos, NM  87545
PH:  (505) 667-8085
FAX: (505) 667-9726
lee_david_w@lanl.gov