How long do we keep records

["Denis J. Rinkacs, Jr." <dr4i@MAIL1.andrew.cmu.edu>]

All,

According to 10CFR20.2106(f) "The licensee shall retain the 
required form or record until the Commission terminates each 
pertinent license requiring this record."

According to 29CFR1910.1020(d) (paraphrase because I don't have it 
in front of me) exposure records from physical agents shall be 
kept for 30 years.

My boss (Director of EH&S) contends that I need to live by the 
OSHA requirement and not the NRC requirement, because he considers 
the OSHA requirement more restrictive.  He says that if I follow 
the NRC requirement, then I open my employer to liability if we 
terminate our licenses and dispose of our exposure records.

1. Is this true?

2. Has this scenerio been tested in the courts? (my bosses 
question)

3. What agency has jurisdiction?  I have a copy of the MOU between 
the NRC and OSHA dated 

----------------------
Denis J. Rinkacs, Jr.
Radiation Safety Officer
Carnegie Mellon University
412-268-3221
412-268-6976 Fax
dr4i@MAIL1.andrew.cmu.edu