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Re: RE: Late charges for unreturned badges
When I see statements such as "let's get real." "good relationship with
PI's,"
or "not becoming an extension of the regulators," I get worried. Such a
"good
relationship" is generally one-sided. If someone is trying to maintain a
good
hp program and running into problems, I understand; but phrases such as
these
indicate that you've given up. If the NRC or agreement state regulators
ever
decided to stictly enforce 10CFR20 for academics and hospitals, you would be
in deep trouble. Whether or not you consider yourself an extension of the
regulators, the RSO is responsible for maintaining the program; and that PI
you have a good relationship with will be diving for cover. As another
response mentioned, even without regulatory enforcement, you could end up
the
target of litigation - even for doses well below regulatory limits. As a
minimum, every incidence of failure to obtain a valid dosimetry reading for
someone who requires monitoring must have a documented investigation to
show:
(1) you best estimate of the dose, and (2) what you're doing to prevent
recurrence.
The opinions expressed are strictly mine.
It's not about dose, it's about trust.
Bill Lipton
liptonw@dteenergy.com
You wrote:
>Let's be real... if you have a researcher who
>has lost a badge and has not worked with P-32 for a month, are
>you going to spend much time beyond an interview to insure they
>have not recieved a potential exposure? No, because they probably
>didn't recieve a dose, but that does not mean they still don't need a
>badge...
...
>My opinion only.
>Patrick McDermott
>Rutgers University
>mcdermot@rehs.rutgers.edu
Hi all,
Bill, I think you came down a little hard. Having problems with lost
and unreturned badges (especially in the University community) is
nothing new and MANY are looking for ways to IMPROVE their
programs. RADSAFE should be a resource to help all involved by
sharing experiences. Let's be real... if you have a researcher who
has lost a badge and has not worked with P-32 for a month, are
you going to spend much time beyond an interview to insure they
have not recieved a potential exposure? No, because they probably
didn't recieve a dose, but that does not mean they still don't need a
badge... They may work with 20 mCi next week. However, if
someone in your Cardiac Cath. lab loses a badge, you will spend
considerable effort because of the relative risk of recieving a
dose...It seems that Andrew Karem does this.
My opinion only.
Patrick McDermott
Rutgers University
mcdermot@rehs.rutgers.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. However, a
<monitoring program that is not taken seriously is worse than no
<program at all, since it becomes an enabler of poor, and possibly
<illegal, practices.
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