Suggested State Regulations
Why are regulations
developed?
National Issue
New Technology
Crisis
Special Interest
Groups
Moral Consciousness
Federal Mandates
What are they and why do you care?
Debbie Gilley
ChairChair- Elect
Conference of Radiation Control Program
Directors
August 1, 2006
CRCPD recognized the need
for consistent regulations
Our mission is to “promote
consistency”
consistency” in addressing
and resolving radiation
protection issues
Our History
Begin with the agreement state initiatives in
1959
Fragmented states initiatives, some more
comprehensive than others in the 1960’
1960’s
1968 CRCPD established as a nonprofit,
nonnon-governmental organizations dedicated
to radiation protection
Established a forum for states to discuss
important issues and initiatives and to share
resources
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EARLY LIFE
TODAY
Annual meeting for states and federal
partners to get together and formalize
regulations based on sound health
physics principles, shared ideas and
develop regulatory framework
What kinds of
regulations?
Our structure
Membership
Board of Directors
Radiation Advisory
Healing Arts Council
Env. Nuclear Council
SSRCR Council
Homeland Security Council
General Council
CRCPD continues to provide the same mechanism
for sharing of information but now includes federal
partners, international friends, and stakeholders
participation in developing regulations, policies and
positions
CRCPD is the mechanisms states use to share
common concerns, problems and resources. We
have compacts and partnerships
CRCPD is recognized as a certifying entity
establishing basic minimum requirements in the
field of health physics and radiation protection.
CRCPD is the only association that addresses all
radiation protection issues
Must be related the to the safe use and
control of radiation sources (devices and
material)
Must be evaluated for radiation safety in
protecting the public, the worker and the
environment
Must be based on good health physics and
radiation protection science
Must be practical, taking into consideration
the beneficial uses of radiation
OED
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Suggested State
Regulations for Control of
Radiation (SSR)
Currently 24 working groups
Membership is composed of CRCPD
members with technical background and
experience in the topic (Voting Members)
Advisors who can be CRCPD members,
affiliate members, manufactures
Resource Individuals, technical experts,
federal and international partners and
professional organizations
The Process: Phase One
Identify need
for regulations
Identify committee
members and
areas of expertise
The Process: Phase Two
OED performs
technical review
Returned Regulations
and Rationale to the
Committee
for review
Committee
Response
to comments
Document
sent to the
CRCPD Board
for approval
Committee begins
the development
of the regulatory
language
Regulation
Modified
by Committee
Regulations sent to
federal partners
for concurrence
Counsel Chair develops
charges and identifies
timelines and milestones
Develops
Regulations and
Rationale Document
The Complex Version
Comments
Part &
Rationale
Start
Regulations
Peer Reviewed
Identify which “current”
committee
should be tasked
with the development
of the regulation
Compiled Needs
OED
Tech
Review
&
Formatting
Development
by
Committee
Response
to
comments
Document
Ready?
Peer
Review
Document
has been
Peer Reviewed?
N
O
Comments
Publish Revised SSRCR
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Advantages
Federal Review
Comments
Expertise with “hands on”
on” experience
setting standards through regulations
Many opportunities to comment on the
proposed regulations
no
Document
has been
Peer Reviewed?
Part, rationale,
remaining comments
CRCPD
Board Review
Accepted
no
Document
has
Federal
Concurrence?
Publish
Revised
SSR Part
Close out
report
Advantages
No federal notification constraints,
regulatory process is transparent and
open.
Have the ability to evoke members
only meeting if conflict of interest
occurs.
–
–
–
–
Member
Advisor
Resource Personnel
Peer Reviewer
The ability to gain support from federal,
international and professional partners in
the initial phase of development
Disadvantages
Time consuming
Requires written rationale and
justification
The conference does not have
dedicated staff solely for developing
regulations
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Amending existing
regulations
Expedite minor changes
Speed up the process
Eliminate some of the peer review
processes
Ease of adoption for compatibility
issues
Success Stories
Part G, Radioactive Materials in the
Healing Arts
Part X Radiation Therapy Equipment
Part F Radiation Machines
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