I find it interesting that our Agreement State Regulations do not have the same first paragraph as 10 CFR 19 which you have written as "This is the section..." Instead our regulations say "All individuals working in or frequenting any portion of a restricted area: shall " etc... rather than "when a worker exceeds the 1 mSv (100 mrem) threshold:" So on the federal level there is a 1 mSv yearly limit, and in our state, everyone entering a restricted area has to have some instruction.
The way this is written, radiation workers not likely to receive the 1 mSv limit in a year do not require instruction listed in 19.12. We have many researchers who do not, and will not receive this limit, yet all are trained as part of our state and license regulations.
From Q411 on the Health Physics Questions at http://www.nrc.gov/NRC/NMSS/HP/QA/qa411.html the text says " (Thus, 10 CFR 19.12 does require instruction of anyone working in a restricted area, even if that work is infrequent.)"
How does this fit with "radiation worker" if anyone
entering a restricted area must be
trained and any dose received in this restricted area is an occupational
dose ?
Thanks for the help.
Steve Hand
Radiation Safety
University of Maryland
Sandy Perle wrote:
This is the section of Part 19 that defines what must be done when
a worker exceeds the 0.1 mSv (100 mrem) threshold:§19.12 Instructions to workers.
(a) All individuals who in the course of employment are likely to
receive in a year an occupational dose in excess of 100 mrem (1 mSv)
shall be—
(1) Kept informed of the storage, transfer, or use of radiation
and/or radioactive material;
(2) Shall be instructed in the health protection problems
associated with exposure to radiation and/or radioactive material, in
precautions or procedures to minimize exposure, and in the purposes and
functions of protective devices employed;
(3) Instructed in, and required to observe, to the extent within
the worker’s control, the applicable provisions of Commission
regulations and licenses for the protection of personnel from exposures
to radiation and/or radioactive material;
(4) Instructed of their responsibility to report promptly to the
licensee any condition which may lead to or cause a violation of
Commission regulations and licenses or unnecessary exposure to
radiation and/or radioactive material;
(5) Instructed in the appropriate response to warnings made in
the event of any unusual occurrence or malfunction that may involve
exposure to radiation and/or radioactive material; and
(6) Advised as to the radiation exposure reports which workers
may request pursuant to §19.13.
(b) In determining those individuals subject to the requirements of
paragraph (a) of this section, licensees must take into consideration
assigned activities during normal and abnormal situations involving
exposure to radiation and/or radioactive material which can reasonably
be expected to occur during the life of a licensed facility. The extent of
these instructions must be commensurate with potential
radiological health protection problems present in the work place.Sandy Perle
E-Mail: sandyfl@earthlink.net
Personal Website: http://www.geocities.com/capecanaveral/1205"The object of opening the mind, as of opening
the mouth, is to close it again on something solid"
- G. K. Chesterton -
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