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Re : Dose estimates when dosimetry is lost/damaged



     Fellow Radsafers,
     
     As a former nuclear power plant health physicist, and
     now a regulator involved in the approval of
     dosimetry services operating in Canada, I can assure you
     that I would expect Dosimetry Services and Users of
     Dosimetry Services to operate in a manner similar
     to what Sandy has outlined.
     
     I applaud Sandy for correcting a situation which I would
     call unacceptable.
     
     Jim Presley
     Health Physicist
     Atomic Energy Control Board
     presley.j@atomcon.gc.ca
     
     
     
     
     
     Date: Wed, 18 Dec 1996 08:02:06 -0800
     From: "Sandy Perle" <sandyfl@ix.netcom.com>
     Subject: Dose estimates when dosimetry is lost/damaged
     
     The practice of dose estimates when dosimetry was either lost or 
     damaged, during my 22 years as a power reactor health physicist, was 
     to conduct a dose investigation based on survey data, secondary 
     dosimetry, dosimetry results from others who worked with the 
     individual in question and most importantly, an interview with the 
     individual. This investigation led to a dose estimate which was first 
     discussed with the individual, a signature obtained from the 
     individual signifying that the investigation was conducted, what the 
     resultant dose was and that the individual concurred with the dose 
     estimate. What I am finding in the world of commercial dosimetry and 
     what the customers want is well beyond this, and a practice I find 
     disturbing at a minimum.
     
     I have learned that many of the current dosimetry processors, as well 
     as the former Siemens Dosimetry service, routinely provided their own 
     estimate to the customer when a dosimeter was lost or damaged. They 
     would base this estimate on the previous two or more dosimeters. This 
     estimate is based on the assumption that the previous work history 
     and doses assigned are indicative and correlated well to the current 
     time period. I find this practice to be disturbing, for many reasons 
     I will elaborate on. Let me also state that it is my policy that my 
     operation will not provide an estimate for any lost or damaged  
     dosimeter. The methodology is simple as to how this is accomplished, 
     who initiates the estimate and how it is documented. 
     
     In my opinion, when a processor provides an automatic  dose estimate, 
     the following problems are evident:
     
     1. Isn't it the responsibility of the individual who is monitored to 
     be cognizant of their radiation exposure?
     
     2. Isn't the RSO or whoever is accountable for the dosimetry program 
     accountable as the caretaker of the individual's doses, to ensure 
     that they are as accurate as possible, and if there is a question 
     regarding an individual's dose, that they become an integral part of 
     the investigation which results in a dose estimate to be assigned?
     
     3. IF a processor automatically assigns an estimate, automatically 
     without any intervention from the customer, isn't this a liability 
     issue, and could within all probablility, end up in litigation some 
     time later?
     
     4. How is the individual notified that their dosimetry was damaged 
     during processing, and that an estimate has been assigned? How are 
     they informed of the methodology used to arrive at the dose estimate?
     
     5. How do the regulators look at a dose assigned without any 
     intervention from the customer, especially without any documented 
     investigation?
     
     6. The processor takes on a serious liability without a detailed 
     audit trail which shows the chain of command of the dose assignment 
     process ... if, there is this automatic dose estimation without any 
     intervention from the customer, who I believe should be legally bound 
     to defend the dose assigned, with the assistance of the processor.
     
     The policy I have implemented is as follows. While it is one that is 
     much different than what our customers have been used to, it is one 
     they agree with after the policy and reasons for it are discussed 
     with them. As in all things, effective communication is required.
     
     
     1. If after a dosimeter is processed, and the flag and intervention 
     reports are run, and it is determined that the dosimeter either is 
     damaged, had an erroneous processing or some other anomaly is 
     identified, the customer is notified and a discussion ensues to 
     assist the customer in providing  us with a written estimate of what 
     the most likely dose is, and when it is entered in our database, it 
     is identified as a "customer provided dose estimate".
     
     2. If a customer calls and requests that a dosimeter be reevaluated, 
     and that evaluation determines that the resultant dose is accurate, 
     the customer must request in writing that a different dose be 
     assigned and their reason for the request. The dose is changed in the 
     radiation history file, the original dose is maintained as one that 
     was the result of the processing, and the file is noted that the 
     estimate was provided by the customer. This is necessary to protect 
     both the customer as well as my operation from liability issues.
     
     3. If a dosimeter is lost or not returned, it is again the 
     responsibility of the customer to provide us with a written estimate 
     for the dose to be assigned.
     
     If one thinks about this logically, it is NOT very difficult for an 
     individual, who is aware that a high dose was received, or that a 
     procedural violation has occurred, to simply "lose" the dosimeter or 
     "damage" it in some was to cause an estimate to be assigned. In this 
     event, to assume that the current dose is equivalent to previous 
     exposures without an investigation in my opinion is reckless and 
     brings into question the entire dosimetry processing program. It is 
     critical that when a dose is assigned to any worker, that the utmost 
     in care be assured to arrive at a reasonable representation of an 
     individual's dose. In a "litigation happy society" it is essential 
     that we, the health physics community" ensure that doses are treated 
     with respect, accuracy and a thorough understanding and practice 
     based on sound methods.
     
     Comments from the group will be appreciated.
     
     
     Sandy Perle
     Director, Technical Operations
     ICN Dosimetry Division
     Office: (800) 548-5100 Ext. 2306 
     Fax: (714) 668-3149