Re: Medical examination for a radiation worker

["Sandy Perle" <sandyfl@earthlink.net>]

> 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

John,

We're quibbling over semantics. Yes, section 19.12 does not say 
"radiation worker." However, it excludes the individual from any 
further scrutiny, training or otherwise. In essence, a DeMinimis 
value. As far as providing dosimetry, there need be none as well, in 
that the threshold requiring that is 500 mrem/year. 

Whether or not the individual should get training is a different issue 
compared to "required" to be provided training. If it is prudent, the 
facility should provide training, but that is at their discretion, taking 
into account the facility, potential for risk, considerations of 
potential litigation, etc. But whether or not they are required to do 
this, is all that I am showing with 19.12.

The bottom line still remains, how much need be put forward when 
there is no dose, no risk for dose and there has been an 
assessment made that says that they will under no 
circumstances, exceed the 100 mrem threshold. That is all 19.12 
addresses. If you want to call the individual a radiation worker, fine. 
I don't have a problem with that. The NRC only says that you need 
not be concerned with the individual. Simple as that.

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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