The radiation programs in the Michigan Departments of Community Health (MDCH) and Environmental Quality (MDEQ) both use the "Ionizing Radiation Rules" promulgated under authority of the Public Health Code, Act 368, P.A. 1978. These rules are out of date and not in conformance with national and international radiation protection standards.

Completing a much-needed overhaul of the Ionizing Radiation Rules is an important step in modernizing Michigan's radiation protection programs. Additionally, Governor Jennifer M. Granholm has directed the DCH and the DEQ to pursue an Agreement with the U.S. Nuclear Regulatory Commission (NRC), and the two departments are preparing for a reconsolidation of the two programs.

This is the first step in a lengthy rule-making process. The formal public review and comment period will be held when the comprehensive package of new rules is formally proposed for promulgation. Meanwhile, we are seeking comments from licensees, registrants, and other stakeholders during these early stages of revising these rules. We hope to identify and resolve issues and concerns before the formal public review period.

We are using the text from the "Suggested State Regulations for Control of Radiation" (SSRCR) of the Conference of Radiation Control Program Directors as the starting point of our revised rules. Our approach is to carefully compare the SSRCR to the language of the corresponding part of the NRC's regulations. We are also examining the rules from other Agreement States. The suggested changes to the SSRCR text in the document are identified by underlining inserted text and striking out deleted text. References to other rules within each part refer to other parts of the SSRCR. Notes are included to explain many of the changes. Specifically noted are instances where the draft rules significantly differ from the requirements of the corresponding federal regulations.

The Legislative Service Bureau has issued guidelines to standardize how rules will be written in Michigan. Many of the minor wording changes from the SSRCR in the draft rules are due to this guidance. We are also making additional wording and grammar changes for clarity and readability.

Please contact us if you have general comments on this rule-making effort, or specific comments on a particular part. Comments regarding mammography and X-ray programs should be sent to John Ferris, MDCH (jeferri@michigan.gov). Comments regarding radioactive materials programs should be sent to Bob Skowronek, MDEQ (skowronekr@michigan.gov). Generic comments may be sent to either.

July 10, 2008