U.S. Nuclear Regulatory Commission
Technical Assistance Request, Continental Airlines, On-the-Job Training of Radiographers
Title: Technical Assistance Request, Continental Airlines,
On-the-Job Training of Radiographers
See the memorandum from J. E. Glenn to R. R. Bellamy dated
August 1, 1991 in response to a TAR from Region I.
Continental Airlines proposed to designate individuals as
radiographers who had completed only 360 hours of
on-the-job training (OJT) verses the 520 hours normally
expected of NRC licensees.
Continental maintained that because it would use only one
type of radiography device and because of the repetitive
nature of its radiography operations, 360 hours would be
sufficient to qualify an individual. Continental also
pointed out that only 45 days (or 360 hours) was the amount
of OJT "agreed to with the state of Texas under
Continental's Texas license (in fact, Texas' regulations
specifically require two months OJT), amd that Continental
was also conducting similar radiography operations under
California and Colorado licenses in those states.
Colorado's regulations imposed a one month period for OJT
that was based on a revision of the Conference of Radiation
Control Program Director's "Suggested State Regulations."
The State of California as determined by NRC required
Continental to provide for 520 hours OJT.
The NRC normally requires 520 hours to qualify an
individual as a radiographer and felt it inappropriate to
waive this "requirement" based only on current job
Therefore, the burden is on Continental Airlines (the
applicant) to show that 360 hours will be adequate to fully
qualify an individual as radiographer. Factors such as
hardship (where an individual is only infrequently involved
in radiographic operations and to obtain the 520 hours will
entail a period significantly greater than three months),
number of procedures, and the quality of supervision and
testing should be considered by the applicant.
Regulatory references: 10 CFR 34.11, 10 CFR 34.31
Subject codes: 1.2, 11.1, 11.3
Applicability: Byproduct Materials