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Re: Medical examination for a radiation worker
- To: radsafe <radsafe@romulus.ehs.uiuc.edu>
- Subject: Re: Medical examination for a radiation worker
- From: "John R. Laferriere 671-8316" <John.R.Laferriere@dupontpharma.com>
- Date: Wed, 21 Apr 1999 09:41:05 -0400 (EDT)
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Sandy wrote:
"John,
You're interpreting what you believe the intent to be. You are
ignoring what the reg says....
The rule only says WHO must be trained (which implies who need not be)."
Sandy- It's your interpretation of 19.12 as implying that the NRC doesn't
believe anyone getting <100 mrem/yr needs any training that I have a problem
with. A licensee who goes by your interpretation and elects not to train low
dose workers because they think the NRC will be fine with that is taking a big
risk. Granted, the NRC says they don't have to have the full soup to nuts
as specified in 19.12, but it does not say no training is necessary. It
leaves it up to the licensee. The NRC would be foolish to tell licensees
explicitly that low dose workers don't need any training. Anyone working in
a restricted area needs training on protective clothing requirements,
contamination monitoring and contamination control measures, posting and
labeling rules, etc. etc. etc. Just because they don't get much dose doesn't
mean you can justify leaving them in the dark on these basic subjects. It's
not about LNT, it's about basic radiation safety, compliance, and perhaps
liability control too. As Warren Church said, it's often the low dose
people who have the most fears and need more information on risks to clarify
the situation.
I'm not ignoring what the regs say. You are reading too much into what they
say. They don't say "don't bother training anyone getting less than 100
millirem/yr." A licensee who thinks 19.12 says that is asking for trouble.
Maybe we're not as far apart on this as I think we are, but it's an important
issue that warrants clarification.
John Laferriere
john.r.laferriere@dupontpharma.com
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