RE: DOE 10CFR835 Question

["Sandy Perle" <sandyfl@earthlink.net>]

> Would you necessarily need to have an RWP?  Best practice would be to have
> an RWP in place but there are no longer any "shall" statements that I have
> been able to find that require the use of an RWP for entry into a
> radiological area.  As long as you can demonstrate some "equivalency"
> wouldn't that be enough? 

Chris,

It doesn't really matter what you call it. Whether there is a "shall" 
or not doesn't really go to the issue. The point I am making is that 
if you expect to control work, and ensure that the workers understand 
the requirements for the job, and entry into specific areas, you need 
to have instructions. Verbal instructions are meaningless, and the 
only viable method is for written instructions. If you don't want to 
call the instructions a RWP, call it what you like. The only 
requirement be that the instructions be in written form. Now, if they 
are written, they should be written meeting some procedural 
requirement. There can't be accountability until there is information 
documented, demonstrating that workers are informed, the job is 
performed, and all procedural requirements were met.


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Sander C. Perle					Tel:(714) 545-0100 / (800) 548-5100   				    	
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