Protecting the Worker During NORM Waste Collection

What the article does not reach

Article 7 names no dose limit for the worker and no personal monitoring. It is written as a set of acts, not as a set of numbers. We say this of article 7 because that is the article we transcribed, and we do not read the silence as an absence of duties elsewhere in Qatari regulation.

Clause 2: bags and containers, at the exit

Containers or plastic bags are provided to gather the protective clothing and the contaminated waste on leaving the place of work. The place named is the exit, so the provision is about where the clothing stops rather than about what it is made of.

Clause 5: wetting, once and then periodically

Dry contaminated material is wetted with water to prevent airborne radioactive material from being generated. The clause then adds that the wetting is repeated periodically during the collection work, so it is not a single act at the start.

The word periodically carries no figure in the clause. No interval in minutes or hours is stated, and an operator who fixes one is making a choice that should be written as a choice.

Clause 6: sealing the openings

The openings of equipment that is internally contaminated with naturally occurring radioactive material are closed with a suitable plastic material. The clause states the act and the material, and states neither a time nor a purpose.

Clause 7: a closing sequence in four acts

The clause lists four acts in one sentence and in this order: the contaminated protective clothing is removed after the collection work is finished and before leaving the place of work, the plastic floor is surveyed for radiation, the contamination is removed by ordinary cleaning, and the barrier and the radiation warning signs are taken down.

The order matters in practice. The signs come down last in the sentence, after the survey and the cleaning, and a site that takes the signs down first has not followed the sequence as it is written.

The four clauses in rows

Clause | The act | When | What the text does not fix

Clause 2 | bags or containers for protective clothing and contaminated waste | on leaving the place of work | no size, no colour, no labelling of the bag

Clause 5 | wetting dry contaminated material with water | at the start and periodically during the work | no interval and no quantity of water

Clause 6 | sealing the openings of internally contaminated equipment with suitable plastic | not fixed in the clause | no thickness and no method of sealing

Clause 7 | remove clothing, survey the plastic floor, remove contamination by ordinary cleaning, take down the barrier and signs | after the collection work and before leaving | no instrument for the survey and no acceptance level for the floor

One figure that is not here, and where it is

Dose figures do exist in the decision, in the provision on the temporary store, one for inside the store and one for the ring around it, and they are about that place rather than about the worker at a collection site. The store is treated as a controlled area and the ring as the supervision area, which is the ring around it. Neither term is defined in article 1, so the explanation is ours, and carrying either of them across to the collection work is the error we avoid.

Who does the work, in each place

Article 7 requires that no one other than the trained workers works in the collection area. The article on decontaminating contaminated equipment requires that work to be done by specialists. Two different words in two different provisions, and neither of them names a course or a certificate.

The closing sequence, in the order of the clause

First, the contaminated protective clothing comes off, after the collection work has finished and before anyone leaves the place of work.

Second, the plastic floor is surveyed for radiation.

Third, the contamination is removed by ordinary cleaning.

Fourth, in the order of the sentence, the barrier and the radiation warning signs are taken down. We recommend, as our own advice, that this be last.

Fifth, a caution of our own. The removal in the clause is for whoever has finished and is leaving. Whoever surveys the plastic floor and cleans it stays in protective clothing, or puts on a clean set, and takes it off at the exit.

A count we make before the shift

A crew of three works two shifts on one piece of equipment, and each worker uses one set of protective clothing per shift. Three workers times two shifts is six contaminated sets, and all six have to be gathered at the exit under clause 2. If the yard has put one bag at the exit for the day, it is holding six sets and the operator should have decided in advance that one bag takes six.

The number six is our arithmetic and not a figure in the decision. The clause requires the bags or containers to be provided and says nothing about how many sets one holds. What the count does is turn a word into a quantity that can be checked before the shift rather than after it.

How often must dry contaminated material be wetted?

The clause says the wetting is also done periodically during the collection work, and it gives no interval. An operator who fixes an interval is making a choice and should record it as one.

Why wet the material at all?

The clause gives its own reason: to prevent airborne radioactive material from being generated. Wet material rises as dust less readily. The wetting reduces the airborne material rather than removing it, and the clause makes it periodic.

Where do the protective clothes go at the end of the shift?

Into the containers or plastic bags provided for gathering protective clothing and contaminated waste on leaving the place of work, and the clothing comes off before anyone leaves.

Can the warning signs come down as soon as the work stops?

In the wording of the clause the barrier and the signs come down after the clothing has been removed, the plastic floor has been surveyed and the contamination has been removed by ordinary cleaning. They are last in the sentence.

Does article 7 set a dose limit for the worker?

No. There is no figure of any kind in the seven clauses we transcribed. A dose figure in this decision belongs to the provision on the temporary store, and it is about that place and not about the person.