[ RadSafe ] Dosimetry Reports

[Chris Alston]

Lawrence

This question would better be directed to your director of corporate
risk management or your legal counsel.  I personally do not see that
these records, which are of *occupational* radiation exposure fall
under HIPPA regulations.

However, there are still issues of privacy for individuals.  Some
people are abandoning the practice, once widespread to the point of
universality, of posting group reports in the workplace, even after
deletion of identifiers such as DOB and SSN.  I believe that someone
at a university in the Midwest won a six- or seven-figure judgement
against an institution for posting the individual's name and
dosimetric data, in the fairly recent past.

Cheers
cja


---------- Forwarded message ----------
From: Lawrence Jacobi <rjacobi at jacobiconsulting.net>
Date: Tue, Apr 17, 2012 at 10:26 AM
Subject: [ RadSafe ] Dosimetry Reports
To: radsafe at health.phys.iit.edu


Are OSL dosimetry reports showing personnel doses to individuals,
whose names are listed on the report, subject to the privacy
provisions of HIPAA (the Health Insurance Portability and
Accountability Act)?  The personnel director for one of my clients has
determined this to be the case.  In some facilities I have visited
recently, the dosimetry reports are posted on the bulletin board in
the break room or near the NRC Form 3 Notice to Workers for all to
see.  She treats bioassay reports the same way.  I don't have an
opinion either way, as I can see merit in her analysis.  But, this is
a new one to me.

Any comments or advice?
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