I agree with previous comment regarding the need for Office of Radiological Health (ORH) staff to engage the regulated community via “town hall” meetings, regulatory information on ORH website and attend professional meetings such as local chapters of the Health Physics Society and American Association of Physicists in Medicine.

The comment regarding the sharing of proposed regulations in the formative stage may have some basis in the Code of Virginia:

§ 32.1-228.1. Department designated state radiation control agency; powers and duties.

B. The Department shall:

c. Establishing and maintaining a file of all agency rules and regulations related to regulation of sources of radiation, pending or promulgated, and proceedings thereon.

I see no reason why the pending regulations cannot be shared with the regulated community as suggested by a previous commenter.

I agree with comment regarding exemptions for certain excreta. There was an outpatient treated with I-125 and the patient had the sniffles. Tissue went into the trash and set off the radiation detector at the municipal landfill. The tissue was traced back to the patient and waste service threatens termination of waste disposal service. Patient was not provided adequate instructions, though not always possible to cover all situations.

I encourage ORH staff refrain from repeal and replace 12VAC-481 for reasons cited by previous commenter. It would also be helpful to use same format and verbiage as the “Suggested State Regulations” published by the Conference of Radiation Control Program Directors, Inc., except in the case of radioactive materials where the U.S. Nuclear Regulatory Commission takes precedence. Uniformity of the regulations were possible would be helpful to those familiar with regulations of other states.