RE: RE: Late charges for unreturned badges

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

-----Original Message-----
From: Dunn, Wes [mailto:WDunn@intiso.com]

Andrew, the wording is "likely to receive", not "potential to receive".  As
such, one can easily justify not badging a large number of individuals by
applying the regulation.  The fact that many/most facilities choose to
over-badge should not be blamed on the regulations.

----------------------------

As written in the regs, this is correct.  However, the State of New York, in
their Model Personnel External Exposure Monitoring Program, states: 

"Personnel monitoring devices should be provided for individuals who are
exposed to sources of whole-body radiation or who handle milliCurie
quantities of energetic beta or gamma emitting radionuclide."

Accordingly, researchers who have permit limits in excess of 1 mCi for P-32
(for instance) should have badges, even though we all know that their
whole-body dose is going to be minimal.  And, lest someone else mention it,
I know the difference between "should" and "shall" in both the English
language and the regs.  But I also know that, in the regulatory world, these
words are more often viewed as synonyms, and this appears to be one of those
instances.  If anyone from the NY Department of Health is reading and would
care to correct me on this, I would love to be able to save our researchers
some money since our dosimetry costs are billed directly to them.  However,
past experience (outside of NY) suggests that we are not likely to receive
regulatory relief on this issue.

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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