Positions & Resolutions

Conference of Radiation Control Program Directors, Inc.

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Rulemaking/Suggested State Regulations
Positions & Resolutions
 

CRCPD RESOLUTION
[May 10, 1995]

Relating to:

Requirements for industrial radiography certification and the two qualified person crew in the final revision to 10 CFR Part 34

WHEREAS:

The development of the proposed revision to 10 CFR Part 34 is an excellent example to date of participatory rulemaking between the Nuclear Regulatory Commission, the Agreement States and the industry;

WHEREAS:

The three workshops conducted and the availability of the draft proposed rule and the proposed rule incorporated the participatory rulemaking and co-regulator concepts;

WHEREAS:

The requirements for radiographer certification and a two qualified person crew was a consensus reached during the participatory rulemaking process;

WHEREAS:

Executive Order No. 12866 of September 30, 1993, "Regulatory Planning and Review," emphasizes consensual rulemaking and directs rulemakers to substantially expand their efforts to elicit the participation of the entire population affected by rule;

WHEREAS:

The American Society for Nondestructive Testing, Inc. and the Nondestructive Testing Management Association have participated in this rulemaking process, and strongly endorse the position that certification of radiographers is germane and essential to safety, and that the two qualified person crew rule is an essential safety practice;

WHEREAS:

The state of Texas has had the two qualified person crew and the radiographer certification requirements since 1986 in order to protect members of the public from unnecessary exposure, provide an additional mechanism of safety, provide direct accountability on the part of the radiographer, and to require radiographers to demonstrate a minimum level of radiation safety knowledge. A review of Texas data from 1979-1993 shows a steady decline in the total number of reported overexposures to industrial radiographers since 1989, after implementation of those rules in 1988.

WHEREAS:

The U.S. Nuclear Regulatory Commission has approximately 165 industrial radiography licensees, and the state of Texas, alone, has approximately 180 industrial radiography licensees and has tested more than 4,000 individuals;

WHEREAS:

The states of Georgia, Illinois, Iowa, Louisiana, North Dakota and Nevada have incorporated requirements for industrial radiographer certification and the two qualified person crew, and have implemented certification programs;

Now Be It Resolved:

The Conference of Radiation Control Program Directors, Inc. strongly urges the U.S. Nuclear Regulatory Commission to include the two qualified person crew, at field site location, requirement and the industrial radiographer certification requirement in the final version of 10 CFR Part 34. This would preserve the positive experience with the participatory rulemaking process and the co-regulatory concepts established with this rule development.

Accepted by CRCPD Membership on May 10, 1995