RE: Survey frequency and inspection

[Quang Le <quangle@SLAC.Stanford.EDU>]

Andrew Mattox wrote:
<<<The University of Rochester Radiation Safety Office is currently performing
>monthly surveys of all posted laboratories.  I am trying to turn the
>majority of this responsibility over to the researchers so that we can
>start performing less frequent but more thorough inspections.

IMHO you're heading in the wrong direction. I feel strongly that all
required surveys other than daily work area checks should be done by RSO
personnel.

Placing burden back on researchers reduces the level of service provided by
your office (and the perception that you are a service provider as well as
a regulator).

You will also find that it will take almost as much effort to ensure that
researchers are conducting surveys in a timely manner as it would to
conduct them yourself.

Since your survey frequency is defined in your license, you increase
potential for problems during inspections.

You reduce the frequency of visits by your personnel and your visibility.
Our visits frequently trigger questions from lab personnel which they
otherwise wouldn't raise and informal discussions with a strong educational
component.

amattox@mbl.edu>>>



While I can agree with many of Andy's arguments, I also see many benefits in having the researchers/lab personnel do some of the "official" surveys. At my former workplace, we required lab personnel to survey their labs weekly, in addition to our HP regular/required surveys. These "additional" surveys are more structured than the daily surveys but less involved than the HP monthly surveys. Since these are additional surveys, they don't reduce the interaction frequency between HP staff and the lab personnel yet can provide the following benefits:

1) Better the chance of detecting contaminations that may occur during the 27-30 days between HP monthly surveys
2) Since the lab personnel are doing the surveys themselves, they are more aware of areas with potential problems and, hopefully, develop better appreciation for the risk involved. I have encountered many people who do not give much thought to "contamination problems". If we tell them that an area is contaminated and needs to be cleaned up. They clean it up without bothering to know how bad the contamination was or why the area was contaminated (of course, these are mostly minor contamination, HP handles the "bigger" ones). If we make them "find" the contamination, document it, clean it and resurvey to make sure it's clean, then at least we are requiring them to "think" about it more.
3) Lab personnel are less likely to "forget" how to use a radiation detection instrument (don't laugh! it's true. Some people, even veteran rad. workers, forget how to use a GM detector properly)
4) If the lab personnel have questions, they will likely come to you for advice therefore increase the interaction frequency and give HP staff a good chance to be a "coach"
5) Break and, hopefully, chance the notion that "radiation safety" is HP's job!
6) Avoid more serious headache that the "minor" contamination can cause if gone undetected.

We were lucky to have complete management's support in instituting these additional surveys. They also took some extra time on our part at the beginning to make sure things are done correctly. But I think this proactive approach will pay off in time and efforts saved from having to deal with larger problems later on.
______________________________________________________________________________
Quang Le
SLAC/OHP
(650) 926-2610
(650) 849-9559 - pager
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