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”. 
 

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. 
 

It will be important to clarify what is meant by 'all documents applicable to the radiation device'. Commercially-sensitive information is included with each application package for device certification to the CNSC.

To say that a transferor must provide "all documents applicable" without a definition of just what that means may result in significant problems in interpretation, particularly with commercially-sensitive / proprietary information.
 

If the specific types of documents that must be provided to a transferee are not defined, there may be significant impacts related to the protection of sensitive / proprietary information on design aspects of a certified device.