[ RadSafe ] Dosimetry records

[Kenneth Marshall]

We eliminated Social Security Number ID altogether as well as any 
documented Date Of Birth for dosiemtry records (for over 5 years now).  We 
use a unique employee ID#.

With State Agencies, FDA GMP and other agency  audits, this has been 
routinely questioned if it is a "medical record" and we counter with that 
it is occupational monitoring (e.g. Industrial Hygiene) an would be the 
same as record of agents of exposure in the workplace (chemicals, noise, 
etc) and this has usually left auditors satisfied.  Ask if your employer 
also considers noise studies with dosimeters "medical records".

With the electronic statements on Instadose, we don't post reports on the 
wall - Employees login with their own secure ID and see only their data. 
This helps immensely - If its not on the wall - its not subject to as much 
audit scrutiny.

If the dosiemtry manager sees elevated employee dose values, we follow-up 
with a standard form asking the employee to offer up reasons for the 
elevated exposure -  that may be "not occupational" its completely 
voluntary, but I have yet to have anyone refuse.

-Ken

Kenneth Marshall
Carestream Health 
Corporate Radiation & Laser Safety Officer







From:   "Perle, Sandy" <sperle at mirion.com>
To:     "The International Radiation Protection (Health Physics) 
MailingList" <radsafe at health.phys.iit.edu>
Cc:     "radsafe at health.phys.iit.edu" <radsafe at health.phys.iit.edu>
Date:   04/18/2012 05:14 PM
Subject:        Re: [ RadSafe ] Dosimetry records
Sent by:        radsafe-bounces at health.phys.iit.edu



In all my years this was not a concern until the past years. We now only 
display  last 4 digits of SSN. The lint can request total info with full 
SSN. Electronic distribution of data to individual with security 
eliminates all of this

Regards,

Sandy Perle
Sent from my iPhone

On Apr 19, 2012, at 4:19 AM, "Jeanne Haslett" <jhaslett at pikainc.com> 
wrote:

> When I managed a dosimetry program the information was handled under the
> "Privacy Act".  Any information associated with your name or SSAN was 
not
> to be publicly distributed or displayed.
> 
> 
> 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?
> Best Regards,
> 
> *Jeanne Haslett*
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