Re: pregnant x-ray tech

["Gerry W. Kindred" <gwkindred@centerior.com>]

gwkindred@centerior.com

For those that are under the auspices of the NRC, or more specificially,
10CFR20.  A "Declared Pregnant Woman" means "a woman who has voluntarily
informed her employer, in writing, of her pregnancy and the estimated date
of conception".   Only then does the employer have to take compensatory
actions to limit the dose to the fetus.  If the worker chooses to inform
her employer 
of the pregancy, then the employer has to limit the dose (from occupational
exposure
to the embryo/fetus to 0.5 rem (5 mSv) over the gestation period (ref.
10CFR20.1208).
Therefore, a worker does not have a disability as a result of pregancy
regarding 
activities as a radiation worker.   Also included within the regulation are
other 
requirements regarding the radiation exposure rate and monitoring.  I
recommend that
any facility that employs radiation workers consider establishing
procedures on the
issue of a "Declared Pregnant Woman" taking into account the legal position
that it 
places on the company, as well as the RSO/Staff.  Keep in mind, that even
if a woman
is obviously pregnant, you cannot legally limit hers or the embryo/fetus
radiation exposure.
This also includes that even if the pregnancy is common knowledge and
openly talked
about, i.e. baby showers, etc.  You cannot limit the radiation exposue
solely because 
of the pregnancy.  SHE MUST INFORM HER EMPLOYER, IN WRITING.

I usually don't put down a disclaimer; however, in this case I will...this
represents my
views and my interpretation of 10CFR20.  I am not speaking for my employer,
the USNRC,
any other person or organization, nor am I trying to practice law.    

gwkindred@centerior.com


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