Re: pregnant x-ray tech

["J. J. Rozental" <josrozen@netmedia.net.il>]

Perfect your approach. This also agrees with the IAEA Basic Safety Standards
Recommendation, Safety Series 115, 1996

I.17 - The notification of pregnancy   shall not be considered a reason to
exclude a female worker from work; however, the employer of a female worker
who has notified pregnancy shall adapt the working conditions in respect of
occupational exposure so as to ensure that the embryo or fetus is afforded
the same broad level of protection as required for members of the public;

Note:

a)  em case of the IAEA-BSS, 1 mSv per year;

b) provide to those workers who could be affected by an emergency plan
appropriate information, instruction and training and keep records of the
training provided;

c) employers, registrants and licensees shall make arrangements for
appropriate health surveillance in accordance with the rules established by
the Regulatory Authority (in this case the NRC, I think)


J. J. Rozental <josrozen@netmedia.net.il>
Israel

=========================
At 12:00 PM 10/13/97 -0500, you wrote:
>

>
>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 
>
>
>
>--Boundary-6605846-0-0
>Content-Type: message/rfc822
>
>Date: 13 Oct 97 10:55:27
>From:"radsafe@romulus.ehs.uiuc.edu" <radsafe@romulus.ehs.uiuc.edu>
>To: Multiple,recipients,of,list,radsafe@romulus.ehs.uiuc.edu
>Subject: pregnant x-ray tech
>Reply-to: radsafe@romulus.ehs.uiuc.edu
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>
>
>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.
>
>
>--Boundary-6605846-0-0--
>
>