RE: RE: Late charges for unreturned badges

[cac04@health.state.ny.us]

     The Model Procedures that Andy is referring to are designed to help
persons with little radiation safety background set up a radiation safety
program that will be acceptable to the Department of Health, and will be in
compliance with Part 16.  The Model Personnel External Exposure Monitoring
Program  basically says that you should badge everyone who is
occupationally exposed to radiation.  However,  10 NYCRR 16.11 states that
"Each person who possesses any radiation source shall supply and require
the proper use of appropriate, calibrated and operable individual
monitoring devices by .... [persons] likely to receive, in one year from
sources external to the body, a dose in excess of 10 percent of the
limits....of section 16.6...", or persons entering a high or very high
radiation area.

     Persons who have a radiation safety background sufficient to make a
determination of which individuals need to be badged according to 10 NYCRR
16.11 do not need to follow the model procedure.  An alternate procedure
describing how you will determine (and document) who requires monitoring
may be submitted to the department for review as part of your license
application.

     Since a lot of large facilities do have problems with timely return of
personnel monitoring devices, we have encouraged many of these facilities
to make a determination of who is likely to receive a dose in excess of 10%
of the applicable limits, and only badge  those individuals.  However, many
people feel more comfortable wearing a badge, and it is difficult to
convince these persons that they don't need to be monitored.  Even if you
continue to monitor these people, once you have made a determination that
monitoring is not required (per  16.11) for these individuals, you are
released from all of the recordkeeping  and reporting requirements listed
in 10 NYCRR 16.6, 16.14 and 16.15.   Again, all of this has to be
sufficiently documented  in order to be acceptable to the department.


**Cynthia A. Costello, CHP
**Associate Radiological Health Specialist
**New York State Department of Health
**Bureau of Environmental Radiation Protection
**Flanigan Square - Room 530
**547 River Street, Troy, New York 12180-2216
**(518) 402-7586      cac04@health.state.ny.us


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