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Re: Reg Guide 8.13

In response to the high plains drifter who wrote:

John, being a CHP and experienced doesn't prevent you from developing, in-house,
a suitable document to inform your employees of the risks.  Nothing says you
have to use RG 8.13 or that you can't use most of the stuff from it in your
document.

High Plains Drifter
magna1@jps.net


That's exactly what we did at the end of '93 when the new regulations
were about to go into effect and there was no new guide or draft available.
We put together our own question/answer format training guide to walk people
through the new regulations regarding prenatal exposure.  It was actually a
useful exercise in terms of extracting and translating all the regulatory
requirements into a user-friendly training document.  

Although you aren't required to use 8.13 as you say above, section D. on
Implementation in the "current" 8.13 states that if you don't use 8.13 material
then you have to propose an acceptable alternative method for complying with
the requirements for instruction of workers.  I doubt many licensees have
proactively gotten NRC to approve their current prenatal exposure training
materials, in writing.  Maybe it can be assumed that the draft guide is
already approved by NRC for training purposes, but the current situation is
a potential liability problem for licensees in my opinion.  And I think it
also puts the NRC in a difficult to defend position when this basic guide
is 5 years late and counting.  Finally, it's a distraction during employee
training when I have to pause to explain why we're giving out a draft guide
with "FOR COMMENT" stamped on it in 14 millimeter high letters.

My opinions only.

John Laferriere, CHP
DuPont Pharmaceuticals Co.
Medical Imaging Division
John.R.Laferriere@dupontpharma.com



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