RE: Declaration of Pregnancy Form

["Geyster, John" <John.Geyster@vynpc.com>]

We have had a Declaration of Pregnancy form in place since the 10 CFR 20
change went into place.  The form also includes a section to undeclare a
pregnancy so that the worker is aware that her limits are being set back
to those allowed under 20.1201.  Both sections require signature of the
individual.

As for the hypothetical question,  past experience has shown that anyone
that is that concerned about the pregnancy will go ahead and declare the
pregnancy.  The only thing the employer can legally due is council the
individual (i.e., train or hand out another copy of Reg Guide 8.13) and
hope the message sinks in.  If you go beyond that, you run the risk of
job discrimination such as the Johnson case.

John J Geyster
Vermont Yankee Corp.
john.geyster@vynpc.com

	-----Original Message-----
	From:	Ken Mossman [SMTP:Ken.Mossman@asu.edu]
	Sent:	Monday, February 09, 1998 5:13 PM
	To:	Multiple recipients of list
	Subject:	Declaration of Pregnancy Form

	Radsafe Colleagues:

	Has anyone developed a "Declaration of Pregnancy" form in
compliance
	with 10 CFR 20.1208?

	A hypothetical question: The Equal Employment Opportunity
Commission
	(EEOC) has interpreted pregnancy to be a disability under the
Americans
	With Disabilities Act of 1990 (ADA) under certain circumstances.
If a
	pregnant radiation worker  seeks accommodations under ADA but
does not
	declare pregnancy under 10 CFR 20.1208, what are the obligations
of the
	institution regarding fetal protection in a radiological
environment? 

	Thanks for any comments. 


	Kenneth L. Mossman
	Professor of Health Physics
	Director, Office of Radiation Protection
	Arizona State University
	Campus Box 3501
	Tempe, Arizona 85287-3501
	Phone: (602) 965-6140/0584
	Fax: (602) 965-6609/991-4998
	E-mail: ken.mossman@asu.edu