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Re: Annual Report to Workers
Thomas wrote:
I would like to pose a few questions to RADSAFE members regarding a
specific aspect of a dosimetry policy. New York State health codes and
regulations ( and I assume other states) specify that "each licensee or
registrant shall advise each worker annually of the worker's exposure to
radiation or radioactive materials...". Here at the University at Buffalo (
Radiation Protection Services), we badge over 450 individuals monthly.
Although we badge these workers, we have documented data to support our
policy of not being required to badge because it is highly unlikely they
would approach ten percent of the annual limit. We badge mainly for
liability purposes as others do I assume. My questions are: are we required
to notify each worker individually at the end of each year? Can the December
dosimetry report which shows the accumulated dose equivalent for the year,
posted monthly in each lab, suffice for this notification? Are we required
to do anything at all? Responses from University type settings and others
would be greatly appreciated.
Agreement state regulations general mirror 10CFR20 which require
annual reports for "each individual for whom monitoring was required".
There is no regulatory report requirement when monitoring is provided
but not required.
Since any reporting which you provide is voluntary (and it certainly
makes sense to report), there is no report format requirement.
The December monthly posting seems to meet your needs.
One caution, if you vendor reports zeros, you should make it clear to
your workers that this value represents a measurement below the minimum
reportable dose for the period and specify that minimum reportable dose
value.
Mike Russell
russelmj@songs.sce.com