Re: Annual Report to Workers

["MIKE RUSSELL" <russelmj@songs.sce.com>]

     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