Re: Soc. Sec. # on Official Records

[Judd Sills <sillsj@GAT.COM>]

At 12:56 PM 6/27/97 -0500, you wrote:
>RadSafers:
>
>It has been our normal practice to include workers' social security numbers
>on each of their official records such as training records...
>
>Lately, more and more people are questioning the need for such inclusion, I
>guess, by fear of misuse (read fraudulent use).  Some people asked why
>can't we use some other  ID number, such as Driver's License #...
>
>If any of you have run into the same situation, I would be grateful if you
>could share your experience and how you handled it.  Do you include SS# on
>every piece of record or just once for each personnel file?
>
>Is there a regulatory requirement to include SS# on training records? I
>remember seeing it but could not locate any. Any reference help here would
>also be appreciated.
>
>Quang Le
>"qmle@icnpharm.com"
>
>
>
The only mandated part of 10 CFR 20, as far as I
am aware that specifically specifies the use of SSNs
in reporitng exposure information is 20.2203,
regarding reporting of over exposures.

"§ 20.2203 Reports of exposures, radiation
levels, and concentrations of radioactive
material exceeding the limits.
* * * * *
(b) * * *
(1) * * *
(iv) Corrective steps taken or planned to
ensure against a recurrence, including the
schedule for achieving conformance with applicable
limits, generally applicable environ-mental
standards, and associated license
conditions.
(2) Each report filed pursuant to paragraph
(a) of this section must include for each individual
exposed: the name, Social Security
account number, and date of birth. The re-port
must be prepared so that this informa-tion
is stated in a separate and detachable
part of the report."

The protection of the worker's privacy is mandated in
20.2106 (see below)
"§ 20.2106 Records of individual monitoring
results.
* * *
(d) Privacy protection. The records required
under this section should be protected
from public disclosure because
of their personal privacy nature. These
records are protected by most State
privacy laws and, when transferred to
the NRC, are protected by the Privacy
Act of 1974, Public Law 93–579, 5 U.S.C.
552a, and the Commission’s regulations
in 10 CFR part 9."

Regulatory Guide 8.7 which discusses acceptable
means to report exposure information via NRC
forms 4 and 5 does have provision for inidividuals
without SSNs in section 1.5 (see below)

"1.5 INDIVIDUALS WITH NO SOCIAL SECURITY NUMBER

     Doses to individuals who do not have a social security number, such as
citizens of foreign countries, should be reported
using another unique identification number. It is important to record the
type of identification used in the data block labeled "ID type"
which follows the "Identification Number" data block on NRC Form 4 and 5.
The appropriate code listed below should be inserted in
the blank labeled ID Type. 
 ID TYPE	               	   CODE
 U. S. Social Security Number        SSN
 Passport Number	                 PPN
 Canadian Social Insurance Number	   CSI
 Work Permit Number                  WPN
 INDEX Identification Number         IND
 Other                               OTH
The use of licensee generated identification numbers should be avoided
whenever possible. "

People that refuse to provide SSNs would do so at possible risk of limiting
the
licensee's ability to obtain a full exposure history, and thus might result in
thier exceeding federal limits during that calendar year.  It would be
advisable to caution them against this practice as multiple identification
codes could come into existence that aren't common to all licenseees that
the worker might be occupationally exposed by.

My opinions...not my employers....blah...blah...blah

Best regards to all