RE: Conundrum

["LANNI, MARC" <MLANNI@entergy.com>]

I believe the way subcontractors are normally
handled(at least at NRC regulated facilities) is that
the "employer" is the licensee as defined in the
procedures for that site...therefore the dose records
would be kept by that site. The Contractor company
may request those records with the individuals consent,
as the way the regulators look at it is - "the individual is
responsible for his own dose" and the licensee is
required to maintain records for dose accumulated
at that particular site
I know tha most of the larger contractors in the 
NPP arena...Westinghouse etc, all have standard
forms to request their peoples dose, and usually
keep a signature on file for that individual.

> Marc Lanni  <mailto: mlanni@entergy.com>
> Grand Gulf Nuclear Station - Health Physicist
> Entergy Operations
> mlanni@entergy.com
> Office:	(601) 437-6572
> Fax:         (601) 437-6573 
> Pager:	(601) 930-8904
> 


-----Original Message-----
From: brackett@bright.net [mailto:brackett@bright.net]
Sent: Tuesday, April 25, 2000 2:22 PM
To: Multiple recipients of list
Subject: Re: Conundrum


Is the person's employer, for whom I assume they're doing this work, an
"outside organization?"  While I agree that dose records are confidential
and should be treated as medical records, if you have subcontractors on
your site their employer is entitled (and most likely, required) to know
what doses they are receiving because they are ultimately responsible.  It
is particularly important if the person has the potential for occupational
exposure at multiple sites.

At 01:53 PM 4/25/2000 -0500, you wrote:
>With the exception of required NRC (or other regulator) reports, an
employee's
>dose history files should not be released to an outside organization
without >the employee's consent.  As a general rule, we treat dosimetry
records as >medical records.
>
>> We recently started allowing non-Lockheed Martin employees to use a large
>> Co-60 irradiator we own. These individuals are required to attend our
>> radiation safety training, be approved by our Radiation Safety Committee
as
>> Authorized Users, and are issued LM dosimetry. Their dosimeter results
come
>> to me mixed in with LM employee's dosimetry results. For privacy
purposes,
>> if an LM employee wants to know their exposure history I require a
written
>> request over the individual's signature. Now I have received a request
from
>> the Human Resources department of the employer of these non-LM employees
for
>> a copy of their dosimetry records "for their files."
>>
>> My question is, do I still require a request from the employee, or do I
send
>> the information to the HR department? How do y'all handle this?
>>

******************************
  Elizabeth M. Brackett, CHP 
     Sr. Health Physicist     
     MJW Corporation, Inc.       
       (330) 644-3757        
  mailto:brackett@bright.net 
******************************
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