The primary focus of most current literature concerning Naturally Occurring Radioactive Material (NORM) is the struggle of regulators trying to gain better control over this material. During the battle to decide who should regulate NORM, related Occupational Health and Safety (OHS) risks have been overlooked. As a result, worker and public exposures to NORM have not been closely monitored or controlled. People charged with managing OHS risks in the workplace understand that their job is not complete until all occupational risks have been identified, evaluated and mitigated or controlled. Are unknown NORM-related OHS risks acceptable to you, your workers or your company? Once the NORM-related OHS risks have been identified and evaluated, a control program must be developed in order to manage those risks. This control program can be incorporated into the overall OHS program at your company. Only then will your company's liability be reduced for future health effect litigation due to occupational exposure to NORM contamination. Clearly, the radiation exposure risk presented by NORM contamination in the Oil and Gas Industry is an OHS risk and should be managed as such. This paper discusses some of the regulatory drivers which mandate that all OHS risks be controlled and outlines a process by which NORM-related OHS risks can be analyzed.

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