Commentaires reçus pour DIS-24-01

Veuillez noter, les commentaires sont publiés dans la langue dans laquelle ils sont reçus.

NomSectionCommentaire
David Shen7.1Proposed amendment: expand the list of exempted medical isotopes. - Gallium-68 and Fluorine-18 which are more common than 66 is missing from the new updated list. Also Ac-225 is starting to gain traction.
David Shen10.13 Section 20, Radiation Survey MetersSome licensees use direct reading dosimeters for other purposes such as Y-90 procedures (to know the injection is complete) or have them for other purposes not for dosimetry. If direct read dosimeters are to be added to this section, it should be clarified who is required to have them calibrated (i.e. industrial radiography, etc). 
David Shen10.20 SCHEDULE 1 (Section 1 and paragraph 38(1)(e)), Exemption QuantitiesThis is a welcomed change, some newer medical isotopes were being defaulted to lower limits resulting in a lower threshold for spill reporting.
David ShenImpacts attendus du DIS 24-01The changes as it stands would create confusion in terms of who would need to calibrate DRDs if they were not explicitly using them for the purposes of personal dosimetry.

Jeff Dovyak RTNM, CRPA (R) 

Radiation Safety Coordinator

Shared Health Manitoba
 

7.2 Proposed amendment: reporting requirements for portal alarm monitors. 
 

(b) file an annual report with the Commission by April 30 that contains a summary of radiation detections for the calendar year before the date of the report; and

 

The existing annual reporting requirement in para 3(3)(b) provides no additional safety benefit, therefore, the CNSC intends to remove this reporting requirement to reduce the regulatory burden associated with shipments of unknown nuclear substances detected while in transport and that emit doses below 5 μSv/h. 
 

No objection! 
 

I am in agreement with the 6th paragraph of Section 7.2, dropping the reporting requirement for an annual detections report – our Licensing Specialist was not sure where to file the last one that I submitted. 
 

Jeff Dovyak RTNM, CRPA (R) 

Radiation Safety Coordinator

Shared Health Manitoba

10.1 New and amending existing definitions:

New definition of “uniformly distributed”

The definition of exemption quantity (EQ) and of unconditional clearance level (UCL), both make mention of when the radioactive nuclear substances are uniformly distributed, however, the term is not defined. As such, the CNSC proposes to add a definition for “uniformly distributed”. 
 

So what is the proposed definition? 
 

Jeff Dovyak RTNM, CRPA (R) 

Radiation Safety Coordinator

Shared Health Manitoba

10.13 Section 20, Radiation Survey Meters:

The CNSC intends to amend this section to require that instruments used for radiation measurements, such as portable radiation survey and contamination meters and direct reading dosimeters must be calibrated within 12 months preceding their use. This amendment would help to clarify the requirement for persons to ensure that their instrumentation is calibrated prior to being used and aligns with section 25 of the Radiation Protection Regulations. 
 

I am most concerned if not alarmed (no pun intended) at the idea of requiring annual calibration of Contamination Meters. This is potentially a huge, unnecessary burden on licensees and a waste of taxpayer money for publicly funded departments. If response to a check source is within expected limits annual calibration should not be required and it is likely that most licensees are doing Efficiency Measurements.

 

I’m uncertain about the propriety & necessity of requiring annual calibration for DRDs, if they are not used as the primary personal dosimeter; for instance if a worker is “badged” with OSLD but wears an EPD during pregnancy for additional surveillance. So while I do not necessarily agree with that, I’m not as opposed as I am for requiring annual Contamination Meter calibration.