RE: RE: Late charges for unreturned badges

["Karam, Andrew" <Andrew_Karam@URMC.Rochester.edu>]

>I am even more astounded at your statement that compliance with monitoring
requirements, "... is >only really a concern with Radiology and Cardiac
Catheterization Lab because of their relatively >high doses."  This implies
that these are the only users who require monitoring.  If this is the >case,
you are probably better off not monitoring the others; perhaps relying on
area monitors to >alert you to changing conditions.  

Dear Mr. Lipton:

The only radiation workers who routinely receive measurable doses are those
in our hospital and the only workers who come close to any limits are those
I mentioned.  However, regulations and regulators require that anyone with
the POTENTIAL to exceed one tenth of the annual dose must be monitored.  The
key word is "potential" as it means requiring badging for people who are
unlikely to ever receive anything close to a dose limit. In fact, when I
worked at the Portsmouth Gaseous Diffusion Plant (while it was still a DOE
site), site HP also acknowledged badging far more people than warranted it
and frequently requested permission to reduce badging to just bona-fide
radiation workers.  Similarly, in Naval Nuclear Power, we badged many more
people than actually received administratively significant doses.  I suspect
that most of us can tell similar stories.  

My one statement you quoted was meant only to acknowledge that we are forced
to badge more users than are at risk of exceeding regulatory limits.  With
regards to management support of our activities, it is greater here than
virtually any other place I have worked (second only to the Navy).  I feel
that your characterization of our program as being, perhaps, too slipshod to
maintain a license is unjustified because it seems based on only this one
statement made in a specific response to a specific question.  I would also
like to point out my statement that personnel not returning their badges
could be suspended from work with radiation or radioactive materials,
something you suggested in your response.  

I have found that it is much easier to achieve compliance with our license
conditions, regulatory requirements, and internal policies by using a
variety of techniques, ranging from gentle reminders through penalties and
sanctions.  My experience has shown that simply cracking the whip on every
offense, regardless of its severity will most likely result in the sort of
adversarial and confrontational relationship that causes people to try to
get away with whatever they can.  This, in turn, is a losing game for
Radiation Safety because we have 1500 rad workers and only 8 Radiation
Safety staff.  I and my predecessors in this position have spent a lot of
time and effort to get to the point of some sort of mutual trust and
confidence with the majority of our researchers.  I am not about to ruin
that by a "one-size-fits-all" approach to any problems that crop up.  At
present, we have one or two problem researchers.  All in all, I think that's
a pretty good percentage.

I would also suggest that the fact that this question arises periodically on
Radsafe could reflect nothing more than the growing discovery of Radsafe by
new members and increasing use of Radsafe by existing members.  I don't
think I have seen this question more than a handful of times in the past
year.  Given the large number of licensees among Radsafe subscribers, this
suggests there is likely not a widespread problem in this area.

Finally, I must say that I was disappointed by your reaction to my posting.
I have always viewed your postings as being generally well-thought out and
worth reading.  I am hoping that this posting was an exception to the normal
quality you have maintained.

Sincerely,

Andy

P. Andrew Karam, CHP
Radiation Safety Officer
University of Rochester
(716) 275-1473 (voice)
(716) 256-0365 (fax)
andrew_karam@urmc.rochester.edu 

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