Re: Medical examination for a radiation worker

["John R. Laferriere 671-8316" <John.R.Laferriere@dupontpharma.com>]

Sandy Perle wrote:

"Paul,

While I don't disagree with you, I'll only state that the reference I 
provided is what the NRC considers a radiation worker, and at what 
extent, "must" they be provided training. 10CFR19.12 also states 
that other factors also need to be be considered, if the individual 
does not meet these requirements. The NRC only says that there 
need not be any training. It doesn't mean that the facility can't 
provide training. The reality is, if there is no dose, and there is 
minimal potential to have a dose that exceeds these limits, how 
much training does one need to provide? I hate to say this, but this 
is the same correlation to LNT.. as to how much do we need to 
spend when there in no measurable benefit to be gained?

The 100 mrem/yr is a projected exposure by the facility.If the 
facility is only providing training because they are "required" to, 
what kind of effort do they put into the program.  My personal 
opinion is, if there is no dose, and the potential to receive dose, or 
the potential to contaminate an area, that may affect others, is 
minimal, why expend the training hours, when that effort should be 
focused on areas that really do need the training, and other 
assistance?"

------------------------
Sandy Perle


Sorry Sandy, but you're wrong.  19.12 doesn't say that anyone getting 100+
millirem/yr is a radiation worker.  19.12 says training is required for 
anyone getting 100+ millirem/yr.  There really is no definition of a 
radiation worker.  There is only a definition of occupational dose vs dose
to members of the public.  The limit for dose to members of the public is
100 millirem in a year, but a person who is engaged in licensed activities
and who gets less than 100 millirem in a year while doing so is NOT a member 
of the public, since they are getting occupational dose.  Likewise, a member
of the public who gets more than 100 millirem doesn't get re-classified as
a "radiation worker".

And while the NRC doesn't require extensive training for low dose workers,
there is certainly a need for training on basic radiation safety and 
compliance issues like contamination control, posting and labeling.  All
it takes is a microcurie of fixed P-32 contamination on the skin to exceed
a regulatory dose limit.

John Laferriere, CHP
john.r.laferriere@dupontpharma.com
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