Re: Annual Report to Workers

[Keith Welch <welch@CEBAF.GOV>]

These are just my opinions: 

At 01:26 PM 11/26/96 -0600, you wrote:
>
. .... 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. 

        Doesn't matter, you monitored them.

We badge mainly for 
>liability purposes as others do I assume. 

I wouldn't say "mainly" but yes, there is the element of "I can't prove that
they were never exposed, so this documents any exposure they 'might' receive."

>My questions are: are we required to notify each worker individually at the
end of each year? 

        YES

>Can the December dosimetry report which shows the accumulated dose
equivalent for the year, posted monthly  in each lab, suffice for this
notification?

        I doubt it.  Unless you have some kind of paper trail that indicates
that people know this is how they are notified of their exposure, and that
these reports (or faximile) are archived for retrieval if necessary.  You
might think about using this method for routine "posted" reports, and
supplement it with individual reports for those with positive doses.  This
way, you are advising the ones exposed on their exposure, and the others can
check the report to verify "lack" of exposure.  This would have to be well
supported with documented training linked to this method so people won't
claim later that they weren't told.


> Are we required to do anything at all?  

        Yes.  You "shall advise each worker annually of the worker's
exposure to 
         radiation or radioactive materials..."  per your regulations.
I don't see any way around it.
 
I would go on a campaign to reduce the number of badged workers, however,
depending on the type of facility and your resources, it may be more cost
effective to keep badging (even though it's a headache) than to implement
the administrative and other controls necessary to replace badging large
numbers of people.
Keith Welch
Thomas Jefferson National Accelerator Facility
Newport News VA
welch@cebaf.gov