Re: Personnel Dosimetry Records

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

>Recently a question of confidentiality of personnel dosimetry records has 
>been brought up.  The question is, if monthly film badge exposures are 
>posted in a department, what, if any, information on the report from the 
>badge vendor should not be posted?  information such as SSN and DOB are 
>assumed not to be posted.  The main question is, each person has a 
>participant number, so should the name also be excluded so the exposure 
>is theoretically known only to the participant?  What right do 
>supervisors and managers have to know the exposures of the people they 
>supervise?  Do occupational radiation exposure records come under the 
>federal Privacy Act?  Any info would be greatly appreciated.
>

The Privacy Act of 1974 applies to federal agencies and contractors of the
US government. Thus, it clearly requires organizations like the Tennessee
Valley Authority (a Federal agency) and Stanford Linear Accelerator Center
(a DOE contractor) to comply. The Act permits any person within the agency
or contractor company to have access to personal data (such as dose records,
SSN, home address) if that person has need of that information to perform
his/her job.

Posting a dose listing with names, SSNs, etc where it can be viewed by
anyone passing by does not comply with the Privacy Act, but sending such
listings by department to the department manager certainly does comply if
that manager has any responsibility for his/her staff's safety (and if not,
why not!).

The 10CFR20.2106 (I think) requirement seeks to provide a measure of privacy
through the NRC's regulations, but that one paragraph does not duplicate the
Privacy Act. DOE-contracted and regulated companies falls directly under the
Act.

Is this sufficiently unclear?

Bob Flood
Stanford Linear Accelerator Center
(415) 926-3793     bflood@slac.stanford.edu
Unless otherwise noted, all opinions are mine alone.