Re: DECLARED PREGNANT WORKER WAIVERS

[bflood@SLAC.Stanford.EDU (Bob Flood)]

A solution in place at a nuclear utility which shall remain nameless seems
to me to have the elements that everyone wants to see. The objective is not
just to provide the appropriate information to those needing it, i.e.,
females and those who supervise. It is also includes lasting documentation
that these people received and understood the information, especially the
right to lower dose limits upon declaration of pregnancy.

The utility maintains a large bank of test questions that are used to
challenge trainees at the end of routine radiological safety training. The
content of the tests are changed routinely to protect the integrity of the
test process. However, the company also has a number of specific questions
on "hot" topics that always remain in every version of the tests. These
cover High Rad Area entry requirements, dosimetry rules, worker right to
talk to the NRC, and prenatal exposure rights, among others.

Tests are reviewed individually with each student. If a test question is
missed, the student is given the correct answer, and the student initials
the test form to that effect. The test becomes a permanent record. If
question arises later, the student's answers on the test can show that a
claim of "they never told me" isn't valid. This usually settles disputes
over incorrect High Rad Area entries very quickly. It should serve the same
function for demonstrating knowledge of prenatal rights without resorting to
a document identified as a waiver.
Bob Flood
Unless otherwise noted, all opinions are mine alone.
(415) 926-3793
bflood@slac.stanford.edu