Re: Conundrum

[brackett@bright.net]

At 09:14 AM 4/26/2000 -0500, you wrote:
>No matter how complex the arrangements, all record transfers, with the
possible
>exception of required regulatory reports,  require the employee's consent.  
>I am not familiar with DOE regs, but I'd have a hard time understanding
how >one organization can be held reponsible for controlling the exposure
of an
>individual being monitored by a different organization.  It seems
advisable to
>administratively allocate dose limits among the different organizations to
>assure that no limit is exceeded.
>

The first statement is not true. The DOE implementation guide for 10CFR835,
Occupational Radiation Protection Record-Keeping and Reporting Guide, says,
under the heading of Privacy Act Considerations:
"No information on an individual should be revealed to anyone other than
the individual, DOE, or DOE contractor personnel who have a need to know
without prior written consent of the individual, unless authorized by the
Privacy Act or for routine uses as published periodically in the Federal
Register. Records of deceased individuals are not covered by the Privacy
Act, but are subject to the FOIA."
Recordkeeping (of doses) at DOE facilities, at least the ones I have
experience with, is a nightmare.  I agree that changes need to be made but
it is not a simple problem. It's easy for outsiders to make sweeping
statements as to how things "should be;" it's quite another thing to face
the actual reality of being on the inside trying to implement the changes. 


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