Re: Disclosure of SSN

[Lester.Slaback@nist.gov]

Sorry to wiegh in so late in this commentary.  I was off doing some
productive environmental studies.  But anyway, .....

I would agreed with the previous comment that we are misusing the SSN. 
Our need for a unique identifier is rather weak. We no longer need to
track doses for a period  longer than 1 yr since that is our only limit. 
Radiation records serve no basis for epidemiological studies since they,
by regulation, represent such a conservative number that they are
basically ficticious in terms of biological effectiveness. Existing
'requirements' for recording the SSN are basically legacy rules [I love
that term.  I covers so many sins!] and hence are not a fundamental
justification for the record.

One argument that was presented is the the SSN is a unique identifier. 
That is true in terms of records, but it certainly serves no purpose in
terms of identifying the individual [which was the intent of the comment].

Regarding Sandy's comment below a small fraction of the licensees have
this  reporting requirement [albeit that they represent a larger fraction
of the workers]. I see no reason for this tail to wag the dog.  If it is a
major issue then NRC should create a Nuclear Worker Identification System
[NWIS] with its own numbering system and require its use.  I suspect this
would not get far given the poor reception a national ID got a few years
ago.

It is probably too late to put the SSN genie back in a private box but why
should we HPs add to the problem?  The use of the SSN to facilitate access
to private information is well documented.  Perhaps abandoning its use in
dosimetry records can be our small contribution to returning it to its
intended use.

Happy Labor Day.


>> I doubt if there is any real reason to use ONLY the
>> social security number for the purpose of keeping track of dose.  

>The primary reason for using the SSN to track dose is that it is a 
>unique number, and, when used properly, the SSN ensures that the dose 
>accumulating for an individual includes all of the dose that should be 
>assigned to the individual. It is also the mechanism whereby the 
>regulators can determine if an individual is attempting to  circumvent
>the regulatory limits by using different IDs. In the case  of the NRC,
>all doses that are sent as required for annual reporting,  and the
>previous requirement for sending termination reports, was  keyed to an
>individual using the SSN. It is the only full-proof  identifier that
>pinpoints an individual.  The excuse that the SSN  could be misused may
>be valid. However, that excuse was also used 25  years ago, when there
>was little evidence of misuse. Even today,  there are no statistics that
>show nuclear workers have been  criminally affected by fraudulent use of
>SSN's.
>------------------
>Sandy Perle
>Technical Director
>ICN Dosimetry Division
>Costa Mesa, CA 92626
>Office: (800) 548-5100 x2306 
>Fax:    (714) 668-3149
>  
>mailto:sandyfl@ix.netcom.com
>mailto:sperle@icnpharm.com

>Personal Homepage:
>http://www.geocities.com/CapeCanaveral/1205
>http://www.netcom.com/~sandyfl/home.html

>ICN Dosimetry Website:
>http://www.dosimetry.com


>"The object of opening the mind, as of opening 
>the mouth, is to close it again on something solid"
>              - G. K. Chesterton -


-- 
the above are the personal musing of the author,
and do not represent any past, current, or future
position of NIST, the U.S. Government, or anyone else
who might think that they are in a position of authority.
NBSR Health Physics
NIST
Gaithersburg, MD 20899
301 975-5810
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Lester.Slaback@nist.gov
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