Re: OSHA radiation regulatory activities

["Busby, Bruce" <bab1303@doh.wa.gov>]

Hi all,

WRT: OSHA regs, notes of interest - 

OSHA Directives - STD 1-4.1 - OSHA Coverage of Ionizing Radiation Sources 
Not Covered by Atomic Energy Act of 1954
  http://www.osha-slc.gov:80/OshDoc/Directive_data/STD_1-4_1.html 

OSHA Standards Interpretation and Compliance Letters at 29 CFR 1910.1096 
  http://www.osha-slc.gov/OshStd_data/1910_1096.html

The following is from a letter by Patricia K. Clark, Director Designate, 
Directorate of Compliance Programs
  http://www.osha-slc.gov:80/OshDoc/Interp_data/I19900927A.html

---quote----

...29 CFR 1910.1096 applies to all workplaces except state and local  
governments, marine terminals, agricultural operations, construction 
operations and workplaces exempted from OSHA jurisdiction by section 
4(b)(1) of the Occupational Safety and Health Act of 1970. Section 
4(b)(1) reads: 

  Nothing in this Act shall apply to working conditions of employees with 
respect to which other
  Federal agencies, and State agencies acting under section 274 of the 
Atomic Energy Act of 1954,
  as amended (42 U.S.C. 2021), exercise statutory authority to prescribe 
or enforce standards or
  regulations affecting occupational safety or health.

OSHA Standard 29 CFR 1926.53 applies to ionizing radiation hazards in the 
construction industry.
That standard incorporates by reference provisions that are comparable to 
those contained in 29
CFR 1910.1096. 

----end quote---------

OSHA also has provisions for anti-discrimination for  whistle-blowers for 
licensees of the Nuclear Regulatory Commission and  an Agreement States 
(plus contractors or subcontractors of licensees), and contractors or 
subcontractors of the Department of Energy.  Namely, 29 CFR 24:  
Procedures for the Handling of Discrimination Complaints Under Federal 
Employee Protection Statutes 
 http://www.osha-slc.gov:80/FedReg_osha_data/FED19980209.html

What seems to be an aspect of this CFR is a required posting that is in 
addition to the NRC form 3 or equivalent.

I have not though heard of OSHA inspections of x-ray and accelerators 
other than in response to employee allegations and concerns.  



--------------------------------------------------------------
Bruce A. Busby    -     Radiation Health Physicist
W- bab1303@doh.wa.gov      H-babusby@aol.com
Rad Prot. Div. - Dept. of Health - Washington State
7171 Cleanwater Lane, Bldg. 5   Olympia, WA  98504

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