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RE: RAM Security
I think I know the "essence " of this discussion but since I missed the
beginning, can someone point me to the specific regs that applies for
security in USA? In Canada, we do have just the same but the inspectors(so
far) consider that a research center with a gard house, card access is
sufficient, as long as no radioactive material is left unattended on a
bench...Of course, this is their interpretation and may change with the next
inspector...
Do you lock rad waste as well ? Our main decay room and storage rooms are
locked but not waste in the investigator's lab.
If I understand the rationale behind the regs, a lab with 3 authorized users
(out of 6 individuals) would have to lock any radioactive quantities (over
your schedule) to prevent unauthorized access from the other 3 persons...
And where do they locate the keys for the padlock ? Or is it combination
locks ? When I was inspector for AECB, I saw some nuclear medicine dept.
keep the keys of the hot lab near...the door where all the other keys are
located (like in most of our houses)
I thank you in advance for your answers because I would like to compare with
other center (about 110 users, 43 labs ) on how they deal with a reg that I
don't find very applicable for biotechnology research environement.
Stephane JF
Specialiste en radioprotection/Radiation Safety Specialist ,RSO
Merck Frosst Canada
Gestion des Risques/Risk Management
) stephane_jeanfrancois@merck.com
% (514) 428.8695
FAX: (514) 428.4917
> ----------
> From:
> Maureen.Gillis@chirondiag.com[SMTP:Maureen.Gillis@chirondiag.com]
> Sent: Tuesday, May 19, 1998 2:56 PM
> To: Multiple recipients of list
> Subject: Re: RAM Security
>
> Could you please describe your security controls? Do you control
> at the point of entry into the lab or with locks and attendance?
>
> At one point, I believe the NRC stated that securing at the area
> entrance created a restricted area so we have stayed away from
> locking the entrances as much as possible.
>
> So, to date we have secured a limited number of areas (e.g. the
> Tracer Manufacturing Area and the Storage-for-Decay Area) and
> locked or attended all other sources using the action levels of
> App. C. (This was found acceptable in a 5/95 inspection with the
> NRC.)
>
> Last week's guidance from the NRC looks like the exception for
> quantities below App. C levels is on its way out.
>
> I would appreciate the comments of others on the strict
> implementation of security controls.
>
> Thank you.
>
> Maureen Gillis
> Chiron Diagnostics Corporation
> E. Walpole, MA
> maureen.gillis@chirondiag.com
> Tel.# 508-660-4207
> Fax # 508-660-4591
>
>
> ______________________________ Reply Separator
> _________________________________
>
> Subject: RAM Security
> Author: "Kenneth W. Price" <75301.361@compuserve.com> at cclink
> Date: 5/19/98 1:26 PM
>
>
> We have a security enforcement program in place which does not consider
> the
> quantity in the research labs. I can envision an "on" again "off" again
> secruity program and investigators stating that they had less than App. C
> qunatities in their areas when we cite them for security. In an active
> research environment it seems impossible to do anything other than require
> that "all radioactive materials" be secured from unauthorized access. Our
> program has worked well and it is very unusual to find a research lab
> unsecured. In the beginning, we had near 15% of the labs being cited for
> security violations. It is now below 1% and very often 0%. Please, no
> comments about natural radioactivity in the glassware or K-40 in each lab
> worker's body. We all know what the intent of the law is, and in the
> current regulatory environment, we have no choice.
>
> Kenneth Price, MPH, CHP
> University of Connecticut Health Center
> Farmington, Ct
> 75301.361@compuserve.com
>