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Texas Radiation Protection Program Outcomes

Texas Radiation Protection Program Outcomes Robert Emery, DrPH, CHP, CIH, CSP, RBP, CHMM, CPP, ARM Vice President for Safety, Health, Environment & Risk Management The University of Texas Heath Science Center at Houston Associate Professor of Occupational Health

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Texas Radiation Protection Program Outcomes

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  1. Texas Radiation Protection Program Outcomes Robert Emery, DrPH, CHP, CIH, CSP, RBP, CHMM, CPP, ARM Vice President for Safety, Health, Environment & Risk Management The University of Texas Heath Science Center at Houston Associate Professor of Occupational Health The University of Texas School of Public Health 1851 Crosspoint Drive OCB 1.330 Houston, Texas (713) 500-8100

  2. Radiation Protection Program Outcomes • Ideally, a public health regulatory control program would rely on health outcome data as its “systemic” outcome measure of performance • But since acute radiation injuries are rare, and latent illnesses possibly not recognized as radiation-related, other “organic” outcome indicators must be relied upon, such as: • Inspection results (violations) • Reported incidents • Reported complaints • Specific events • Misadministration/dose irregularities • Overexposures • Stolen sources

  3. Scope of Texas Operations • Approximately 15,000 registrants of radiation producing devices • Approximately 1,500 licensees of radioactive materials • All permit holders are inspected on a pre-determined schedule

  4. Outcome Data • DSHS maintains extensive records on • Violations • Incidents, complaints • UTHSCH students accessed this data from as far back as 1956 • Format varied from paper, floppy disk, CD • Entered into standardized electronic format • Represents the most comprehensive radiation protection outcome dataset in the nation • What can we learn from the data….

  5. Procedures 11% Absent surveys 10% Leak testing 8% Personnel monitoring 7% Instrument calibration 7% Inventories 6% Transfer records 6% Disposal records 4% Main program 4% Training 2% Licensees: Top Ten Violations 1988-1997 Total† 65% †Annual Top Ten Varied from 55% to 75% of all NOVs

  6. Licensee Top Ten Violations By Year1988-1997

  7. Licensee Violations Severity Level Distribution 1988-1997

  8. OS&P NC/NA 20% Time/temp chart 11% No QC 10% Alignment 7% Annual PE tests 6% Technique chart 5% Reg not current 4% Dosimetry 4% Timer 3% “Other x-ray” 3% Registrants: Top Ten Violations 1988-1997 Total† 73% †Annual Top Ten Varied from 61% to 78% of all NOVs

  9. Registrants: Top Ten Violations By Year1988-1997

  10. Registrant Violations Severity Level Distribution 1988-1997

  11. Texas Compared to Maine and Washington State

  12. Complaints by Permit Type1988-1997 in Texas (n=857)

  13. Complaint Summary1988-1997 in Texas (n=857)

  14. Incidents by Permit Type 1988-1997 in Texas (n=2,126)

  15. Incidents by Work Setting 1988-1997 in Texas (n=2,126)

  16. Summary of Reported Incidents in Texas from 1988-1997 Unauthorized Source Unauthorized Unauthorized Release Use Unauthorized Unauthorized Storage Possession 0% 0% Disposal 0% 0% 3% Transportation Uranium Spill Accident 1% 2% Badge Overexposure Source Stolen 14% Contamination Source Lost 3% 4% 7% Source Found Elevated Bioassay 4% 1% Source Fire Equipment Damaged 1% 2% Source Downhole 2% Improper Storage Source Disconnect 0% 3% Improper Transport Safety Violations 0% Irregularity 0% 8% Radiation Injury Leaking Source 1% 3% Malfunction 3% Overexposure (n=2,026) Misadministration 28% 8%

  17. Total overexposures in Texas, 1970 to 2002

  18. 2000 1800 1600 1400 1200 1000 Number of Licenses 800 600 400 200 0 1970 1975 1980 1985 1990 1995 2000 Year Active Radioactive Materials Licenses In Texas, 1970 to 2000

  19. Reported overexposure events compared to the number of radioactive licenses issued in Texas, 1970 to 2000

  20. Total overexposures in Texas, 1970 to 2002 Radiographer training requirement Regulatory dose limit change

  21. Overexposure Incidents in Texas 1956-2000 By Source (n=2,066)

  22. Overexposure Incidents in Texas 1956-2000 by Dose Rate (n = 2,066)

  23. Overexposure Incidents in Texas by Total Dose, 1956-2000 (n = 2,066)

  24. Rig count in Texas, 1970 to 2004

  25. Rig count 1970 to 2004 and Total overexposures 1970 to 2002, in Texas

  26. Rig count 1970 to 2004 and Total overexposures 1970 to 2002, in Texas Radiographer training requirement Regulatory does limit change

  27. Rig count 1970 to 2007 and Total overexposures 1970 to 2002, in Texas

  28. Occupational Overexposure Incidents in Texas 1956-2000 by Dose Rate (n = 1,983) 17% exceeded annual 5 rem limit 79% exceeded quarterly 1.25 rem dose limit Classic Heinrich’s ratio – for every 1 major accident, there were likely 30 minor events and perhaps 300 unsafe acts. An especially useful concept for rare events, by monitoring for the precursors to the major accident. The problem is…..

  29. Occupational Overexposure Incidents in Texas 1956-2000 by Dose Rate (n = 1,983) 17% exceeded annual 5 rem limit The baseline surveillance indicator of “unsafe acts” for radiation doses is now missing!

  30. Misadministrations & Dose Irregularities

  31. Misadministrations & Dose Irregularities

  32. Misadministrations & Dose Irregularities

  33. Stolen Source Events Fig. 5 Characteristics associated with reported stolen source events in Texas, 1956-2000 (n=113)

  34. Reported Stolen Source Events in Texas, 1956 to 2000 by transporter (n=64)

  35. Summary Observations • The collective performance of the radiation safety profession (inclusive of regulators and permitted community) has been very good, and should be considered a model for other public health efforts. • The ultimate outcome, overexposures, has dramatically decreased as a rate over time. • Longitudinal data analysis affords the identification of some interesting trends and commonalties that can be used to further improve the process

  36. Putting Radiation Risks Into Perspective: The Public Health Significance of Workplace Safety • In 2007 there were: • 5,657 workplace fatalities • That’s 15 people per day that left for work and didn’t come home • 4,002,700 recordable workplace injuries or illnesses • That’s a workplace injury or illness being recorded every 10 seconds • Fires, which are only one of many property “perils", resulting in $14,639,000,000 in direct property loss Sources bls.gov, nfpa.org

  37. Special UT SPH Student Acknowledgment Special thanks goes to the students who collectively worked on the assembly of this data for the benefit of their academic pursuits and the State of Texas

  38. References • Emery, R.J., Pollock, J., Charlton, M., "Notices of Violation Issued to Texas Radioactive Material Licensees Inspected in 1995", Health Physics, 73(4): 706-709, 1997. • Emery, R.J., Charlton, M.A., Goodman, G.R., “Texas Radiation Safety Program Outcomes as Indicated by Regulatory Compliance Activities from 1988 to 1997” Health Physics, 78(3): 335-342, 2000. • Emery, R.J., Charlton, M.A., Mathis, J.L, "Estimating the Administrative Cost of Regulatory Noncompliance: A Pilot Method for Quantifying the Value of Prevention", Health Physics 78(Supplement 2): S40-S47, 2000. • Emery, R.J., Charlton, M.A., Orders, A. B., Hernandez, M. "Using Fault Tree Analysis to Identify Causes of Non-Compliance: Enhancing Violation Outcome Data for the Purposes of Education and Prevention" Health Physics, 80(Supplement 1): S16-S21, 2001. • Charlton, M.A., Emery, R.J., "Radioisotope Misadministration and Dose Irregularity Trends in Texas" Health Physics, 81(5): 585-591; 2001. • Emery, R.J., Orders, A.O., Charlton, M.A. "Piloting a New Radiation Protection Program Strategy: Rewarding Compliance Rather Than Sanctioning Non-compliance "Health Physics, 82(Supplement 1):S18-S22; 2002.

  39. References • Emery, R.J., Orders, A.B., McCrary, J.R., Charlton, M.A. "An Evaluation and Comparison of Compliance Inspection Outcome Data for Radiation Protection Programs in Maine and Texas" Health Physics, 82(3): 395-399, 2002. • Emery, R.J., Orders, A.O., Charlton, M.A., "Texas Dental X-ray Compliance: An Analysis of Trends for the Purposes of Education and Prevention" Texas Dental Journal, 119(9) 916-921, 2002. • Maness, K., Emery, R.J., Casserly, D., “An Analysis of 45 Years of Reported Overexposure Incidents in Texas, 1956 to 2001” Health Physics Journal, 86(2): 197-202, 2004. • Brown, B.J., Emery, R.J., Stock, T., Lee, E.S., “Radiation Protection Program Outcomes as Assessed by the Results of Compliance Inspections in Washington, as Compared to the States of Texas and Maine”. Health Physics Journal, 86(3):308-315; 2004. • Emery, R.J., Valizadeh, F., Kennedy, V., Shelton, A. “An Analysis of Variables Influencing the Number of Radiation Overexposure Events in Texas from 1970 to 2000” Health Physics Journal, in press. • Korshukin, M., Emery, R.J., “An Analysis of Reported Events of Stolen Sources of Radioactivity in Texas from 1956 to 2000 “ Health Physics Journal, in publication.

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