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Re: Conundrum
Just a note-
In Kansas the bare-bones requirement for determination of prior dose is
(KRPR 28-35-212e(c)(1))
"...a licensee or registrant may:
accept, as a record of the occupational dose that the individual received
during the current year, a written signed statement from the individual, or
from the individual's most recent employer for work involving radiation
exposure, that discloses the nature and the amount of any occupational dose
that the individual received during the current year;..."
An example is the traveling Doc who uses his/her own dosimetry-the hospital
still needs at a signed statement about doses received at other facilities
for that year.
DJWhitfill
Opinions expressed are mine and do not reflect official policies or
positions of the Kansas Department of Health and Environment.
"Sandy Perle"
<sandyfl@earthlink To: Multiple recipients of list
.net> <radsafe@romulus.ehs.uiuc.edu>
Sent by: cc:
radsafe@romulus.eh Subject: Re: Conundrum
s.uiuc.edu
04/25/00 05:21 PM
Please respond to
radsafe
> 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.
Liz,
While I am not sure what DOE requires, I do know that under NRC,
as well as state regulations which are based on 10CFR20, the
employer only needs to know (for monitoring purposes) whether or
not the individual will exceed the 10% rule at THEIR facility. If the
decision made is that they do nor, then the employer need not
provide dosimetry, nor, are they required to complete a Form 4 on
the individual.
Personally. I had a problem with this when as a member of the AIF
Committee that met with Bob baker and Walt Cool to discuss this,
that the NRC didn't not require dose from all facilities be
documented when making the decision as to whether or not
monitoring was required, as was the case with the previous Part
20. The comments were that the employer only needed to make a
proactive decision based on their won doses to be concerned with.
As far as the requirement to obtain signatures, I require an
employee signature when one facility requests doses from other
facilities where their employees may also be badged (assuming we
provide the dosimetry to the other facility). However, you would be
surprised how many of these customers, when told of our
requirement, stated that this was not required by other commercial
processors. My comment has been, and is still the case, that if
they want the doses from other facilities, not only do I require an
employee signature, but also from the other employer as well,
since it is THEY who provide for and pay for the dosimeters. This
has not been a problem once they are informed of the requirements.
----------------------------------------------------------------------------------
Sandy Perle Tel:(714) 545-0100 / (800) 548-5100
Director, Technical Extension 2306
ICN Worldwide Dosimetry Division Fax:(714) 668-3149
ICN Biomedicals, Inc. E-Mail: sandyfl@earthlink.net
ICN Plaza, 3300 Hyland Avenue E-Mail: sperle@icnpharm.com
Costa Mesa, CA 92626
Personal Website: http://www.geocities.com/capecanaveral/1205
ICN Worldwide Dosimetry Website: http://www.dosimetry.com
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