RE: Medical examination for a radiation worker

["Daren Perrero" <dmperrero@email.msn.com>]

Its also a little interesting to note how the 100 mrem value got put into
the regulations.  This threshold value was never made available in the
notice of proposed rulemaking.  Instead it was developed as a result of
comments received in the advanced notice.  I don't believe any of the
Agreement States saw (or heard) of the NRC's intention to insert this value
into the regulations.  At that same time, the NRC determined that states who
left the old language in place "All individuals working in or frequenting
any portion of a restricted area:  shall..."  were compatible as they were
allowed to be more restrictive in their wording.

I believe that if one went with strict interpretation of the regulation the
vast majority of personnel at most licensed sites would not have to receive
any training under 10 CFR 19. At the same time I can't believe that would be
in the best interest of any radiation safety program.

Daren Perrero
dmperrero@email.msn.com
I'm with the government, I'm here to help you....

>
> Radsafers:
>
>     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



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