Re: Medical examination for a radiation worker

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

Sandy- I disagree with your interpretation of 19.12 again.  You stated:

" 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....  The NRC only says that you need not be concerned with 
  the individual. Simple as that."

That's not what 19.12 says.  It says you SHALL train people getting 100+
millirem/yr.  It doesn't say you can ignore people getting less than 100
millirem/yr.  My guess is that the NRC put in the 100 mrem trigger level
in order to give licensees a little slack when dealing with contractors for
example, who may be in a restricted area for half a day to service an
instrument.  19.12 now lets you take that person into the restricted area
without dragging them through a multi-hour training session.  

To restate my interpretation of 19.12 once more for clarity, it does NOT
say you don't have to train anyone getting <100 mrem/yr.  It does NOT say
you can ignore individuals receiving less than 100 mrem/yr of occupational
dose.  It's up to each licensee to decide how or whether to train people
getting <100 mrem/yr, and it had better be a careful decision, not one
based on an incorrect and overly simplistic interpretation of 19.12.

Regarding the original question of medical monitoring for radiation workers,
I do not believe that most occupationally exposed workers need it.  Our
company has annual in-house physical exams for workers getting a rem or
more per year, but this is probably excessively conservative.  What does
make sense is medical monitoring for workers wearing respiratory protection,
hazmat workers, etc,.

We are not quibbling over semantics.  We are in significant disagreement
on the meaning of a key section of the NRC regs.


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

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