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100 mrem criterion, radiation worker

One reason NRC made the change to 10CFR19 and to the definition of
occupational dose was that a person, e.g., a member-of-the-public, should
not be categorized as a radiation worker simply by entering a restricted
area.  Once you decide to drop that definition (dating back to the old Part
20) you are faced with how to define Occupational Dose, which is now based
on function (i.e., duties performed).  This then leads to graded training
requirements, and logically to the point that if a worker gets no more dose
than allowed for a member-of-the-public why should the training requirement
related to the rad exposure component of the work be any different than
that for a member-of-the-public.
Similarly NRC not long ago made a change to the threshold requirement for
monitoring of minors (i.e., changing the threshold from 50 mrem to 100 mrem).
Personally I think these changes make for a much more logical and
consistent set of rules.

There are a number of definitions floating around, and folks commonly
associate anyone getting Occupational Dose (as defined by NRC) as being a
RW.  But the fundamental issue is what are the regulatory requirements
related to the definition.  As seen by the previous RADSAFE discussion in
the NRC world there is a large gray area.  That is, while the definition of
Occupational Dose is clear cut (well, sort of) the related requirements for
dosimetry and training are varied, and in some cases minimal to nil.
Similarly, the responses to France query indicate that their medical test
requirements vary, depending on the kind of rad work and level of exposure.
 Hence what is implied by the use of the term Radiation Worker depends upon
the context.  And the context is not the same even among different U.S.
areas (DoE, NRC, state regulated licensees).

Lastly, I assert that at exposures within occupational limits there is no
need for medical exams or medical screening criteria related to the
radiation exposure component of the work.  If you accept the stochastic
model of risk expression and current estimated risk levels I do not see how
one can justify any other position.  [We'll see what that stirs up.  But
that is basically NCRP's position.]

    Subject: Re: Medical examination for a radiation worker
Steve Hand wrote........
    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:"   <snip> ........

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