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Re: pregnant x-ray tech



There seem to be two issues, here: 
 
(1) her "declared pregnant" status - By regulation, this requires you to 
implement the 500 mrem limit, and, by itself, does not prevent her from 
working as an x-ray technician and cannot result in job discrimination.    
 
(2) the note from her physician - This should be handled using you company's 
policy on medical disability.  Do you require a final determination by the 
company's medical department on any medical disability statements by the 
employee's personal physician?  For example, if an employee comes in with a 
note from his physician saying he can't do heavy lifting due to a back 
condition, do you require an evaluation by the company's medical department, 
or do you accept his physician's note at face value?  What is your company's 
policy regarding job status and pay for employees who cannot perform their 
jobs due to medical disability.  (Remember, it's not the pregnancy that would 
prevent her from working as an x-ray technician, but the physician's 
declaration of medical disability.)  Whatever you do for other potentially 
disabling medical conditions should be followed here. 
 
Two additional concerns are: 
 
(1) Since there may be legal issues beyond NRC regulations and common sense, 
be sure that your legal department reviews and clears any decision.  (When I 
screw up, I like to have company!) 
 
(2) This seems to be a precedent-setting decision; i.e., if you give her full 
pay for no work, then you will have to do the same for every other pregnant 
employee with any potential radiation exposure.  Thus, this decision must be 
made very carefully, and must consider elements beyond this individual. 
 
The opinions expressed are strictly mine. 
It's not about dose, it's about trust. 
 
Bill Lipton 
liptonw@detroitedison.com 






I have a pregnant x-ray tech that has provided us a note from her physician 
stating "no work around radiation".  He does not indicate the wearing of 
lead, standing prolonged periods of time, pushing portable machine....just 
"radiation".  She has signed the "declared pregnant worker" form which is 
what I felt obligates us to monitor her (with fetal badge) adequately to 
show that she does not exceed the limits but does not require us to take her 
out as a "radiation worker".

She did not address any concerns about radiation with me as the RSO.  Before 
approaching her and her physician I would like to get other's opinions or 
experiences regarding this.