RywIrooe HON Ses 358 wae RADIATION STANDARDS, INCLUDING FALLOUT 315 ards and operational controls. Such local voluntary controls are responsive to the legal standards but characteristically are more stringent because of the potential for significant exposure and because of the complexities of converting different types of exposure to a common base. A few examples of the kinds of in-plant standards are— (a) Limitations on the radiation exposure which may be received by a worker in any one administratively convenient or necessary unit of time shorter than the formal or codified time base. For example, to assure limitation of radiation dose to individuals to say 3 rems in 13 weeks, it is usually necessary to establish additional internal controls which limit dose to some fraction of 3 rems per week or per month. (b) Requirements for the wearing of dosimeters, protective clothing, respiratory equipment, ete. (c) Guides for the controlled release of radioactive effluents. (d) Calibration requirements of radiation measuring instruments. (e) Formal procedures for action in case of emergencies. Only through the use of such inplant administrative standardsis it practical to implement the generally accepted philosophy of minimizing exposure to radiation wherever possible. Control of this type would be difficult, if not impossible, to achieve under a direct and rigid application of many basic or codified standards. In the situation where there are no statutory or contractual requirements and the user of ionizing radiation is being guided principally by the recommendations of the NCRP, he will usually have an internal set of standards which may deviate in part but require compliance with the general intent of the recommendations of the NCRP. In such cases the principal motivating force is in the quality and the value of the guidance which is offered by the standards. The high degree of voluntary acceptance of the recommendations of the NCRP and the ICRP over the last 30 years is an outstanding example of what can be achieved by the user having high confidence in standards which are offered for voluntary acceptance and application. Another important administrative element is the establishment of a work climate and employee attitudes favorable to good radiological control. Written standards and procedures alone just do not give assurance that people will have the understanding to enable them consistently to do the right thing. Continuing education in the basic intent of protection standards is important. The success of a radiation protection program is, therefore, usually dependent as much or more on the voluntary acceptance of a way of life as upon literal conformance to a rule. PROBLEM AREAS IN INDUSTRIAL APPLICATION OF RADIATION PROTECTION STANDARDS While the development and application of radiation protection standards for control of industrial exposure are not without problems, there are perhaps no eurrent major problems in this area. Within this framework, however, I would like to mention several areas which contain the seed of future problems. The transfer of certain regulatory responsibilities from the Atomic Energy Commission to the States of our Nation has only recently begun. In the States where this transfer has been effected or is close at hand, State regulations generally seek to assure the level of control provided in title 10 of the Code of Federal Regulations for application to licensees. In spite of the intent of all parties to maintain reasonable uniformity within the State regulations, there is considerable opportunity for inconsistencies, gaps, and overlaps between States and between State codes and Federal codes. Some of these, although relatively minor, have appeared. The potential problems which could be encountered by an industrial firm having atomic energy activities in several States, each with differing requirements, and also having licensee relationships and contractor relationships with the Atomic Energy Commission, are obvious. Some problems of reciprocity and jurisdiction have yet to be worked out to minimize the administrative problems of industrial firms. Another problem in the development of radiation protection standards is the format and language of the standard itself. There are divergent viewpoints on the degree of specificity and methodology which should be contained in radiation protection standards. It is important that standards be written as performance standards, or functional specifications, not as a specific detailing of mechanistic or interpretive methods to be used. The radiation conditions encountered by various users in industry differ so markedly that a standard 868538—62—pt. 1——21 giaRAENEESAE NEIRRAELRRERT ye as