Re: Disclosure of SSN

["Sandy Perle" <sandyfl@ix.netcom.com>]

Lester stated the following:

> 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 fictitious 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.

I agree wholeheartedly that radiation records serve no useful purpose 
for and can not be the basis for epidemiological studies. This was 
the conclusion of both EPRI and NEI surveys. I do not agree with the 
comment that we no longer need to track doses beyond a year. While I 
had pushed for the NRC Form 4 only to track current year dose, while 
a member on the NUMARC Radiation Protection Task Force, the final 
rule returned the requirement to document previous lifetime dose. The 
NRC did finally make some amends when it issued Red Guide 8007, 
which stated that the "previous years dose" could be a simple 
acknowledgment by the individual as to what the total dose was, and 
the need to retrieve previous records was not required. However, the 
requirement is there, albeit, a statement that this is Good Health 
Physics practice to attempt to obtain the dose history. 

Since there is only an annual limit, the regulatory agencies should 
amend the regulations to require current year dose only, and that 
would be the end of that. In the event someone wanted their previous 
dose history, they still can request that from all facilities they 
have worked out. All licensees (NRC at least) maintain the records 
for the lifetime of their facility, most lifetime of license + 10 
years. With the discussion regarding risks, or lack of risks, this 
would be a good place to start. Current year records, previous .. 
forget them. Logically, any individual an receive the full annual 
limits, regardless of their previous dose history, regardless of if 
they exceeded an annual limit. Previous history is now a needless 
documentary issue.

I have always been a proponent of the SSN, primarily because it was a 
simple, and concise indentifier. If there is a better method, and one 
that can be used by all licensees, so be it. BUT, that doesn't exist 
yet. Now, if the regulators implement a more sensible radiation 
protection policy, the need for details records will be modified 
somewhat, and, the need to track, the need to report and the need to 
maintain the endless records, this too can be amended. Until such 
time, there needs to be a concise and realistic tracking system, and 
I believe that the SSN (USA) is the only sure proof identifier.
------------------
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:
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