The "As Low As Is Reasonably Achievable" Process

DOE-STD-1098-99

Radiological Control

Excellence in Radiological Control

June 2004

117 The "As Low As Is Reasonably Achievable" Process

10 CFR 835 requires DOE activities to develop and implement plans and measures to maintain occupational radiation

exposures as low as is reasonably achievable (ALARA) [see 10 CFR 835.101 and 835.1001]. As applied to occupational

radiation exposure, the ALARA process does not require that exposures to radiological hazards be minimized without

further consideration, but that such exposures be optimized, taking into account both the benefits arising out of the

activity and the detriments arising from the resultant radiation exposures and the controls to be implemented.

An effective ALARA process includes effective consideration, planning, and implementation of both physical design

features (including engineering controls ) and administrative controls to balance the risks of occupational radiation

exposure against the benefits arising out of the authorized activity. Lessons learned are documented, institutionalized,

and considered in planning and executing subsequent activ ities to further the goals of the ALARA process and to

provide optimal employee protection.

While most or all of the provisions of this Standard support the ALARA process, the provisions of Chapter 3 are

specifically directed toward the planning and execution of work, physical design features and administrative controls, and

efforts to implement work controls commensurate with the radiological hazards.

118 Integrated Safety Management

DOE requires its contractors to develop and implement an Integrated Safety Management system (ISM) that integrates

safety (including radiological safety) into management and work practices at all levels (See DOE Policy P 450.4 and its

associated guidance documents). DOE intends for the provisions of this Standard to be consistent with, and to

complement implementation of, ISM. This Standard supports ISM by providing a system of radiological controls that can

be implemented on a site-wide basis and tailored to meet facility-and hazard -specific needs. This Standard also provides

guidance for increasing worker involvement in identification and implementation of appropriate controls. Like the

ALARA process, an effective integrated safety management system emphasizes the development and implementation of

controls that are comme nsurate with the hazards associated with any specified activity.

Under ISM, both DOE and DOE-contractor line managers are charged with responsibility for integrating safety

measures into all facets of work planning and execution. Line managers should use this Standard as a guide to

integrating radiological control measures into work planning and execution.

This Standard supports the ISM guiding principles as follows:

Line Management Responsibility - This Standard clearly indicates that line management is responsible for

ensuring adequate implementation of the radiological control program.

Clear Roles and Responsibilities - This Standard establishes clear roles and responsibilities for DOE and

contractor line management and for the radiological control organization.

Competence Commensurate with Responsibilities - This Standard provides guidance for providing classroom

and on-the-job training so that individuals may gain and maintain the appropriate competence.

Identification of Safety Standards and Requirements - This Standard provides cross-references to other DOE,

Federal Agency, scientific, and consensus standards that are important to developing and implementing an

effective and comprehensive radiological control program.

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