Re: How long do we keep records

["Sandy Perle" <sandyfl@earthlink.net>]

Regardless of what a regulatory body states with respect to any record that 
pertains to an assessment of a dose, I strongly suggest that they be kept for 
the lifetime of the facility, and beyond, when practical. A facility may meet a 
regulation by maintaining a record for the established time period. 
Unfortunately, a regulatory commitment does not preclude litigation on an 
exposure issue. The regulations, such as 10 CFR, states that meeting the 
regulations will not pre-empt one from litigation. I suggest that you keep any 
record that can be used to reconstruct a dose record. This includes appropriate 
survey documentation, investigations performed, modifications to a dose 
record, and most importantly, all pertinent documentation pertaining to the 
dosimetry worn, and, processing information.

A facility will need all of this, and more, in the event of litigation. Don't go in 
empty handed, stating that the regulatory time frames were met, and we 
destroyed all of the information. That is technical suicide.


------------------
Sandy Perle
Technical Director
ICN Dosimetry Division
Costa Mesa, CA 92626
Office: (800) 548-5100 x2306 
Fax:    (714) 668-3149
  
sandyfl@earthlink.net
sperle@icnpharm.com

Personal Website: http://www.geocities.com/CapeCanaveral/1205
        
ICN Dosimetry Website: http://www.dosimetry.com

"The object of opening the mind, as of opening 
the mouth, is to close it again on something solid"
              - G. K. Chesterton -

The opinions expressed are solely, absolutely, positively, definitely those of the author, and NOT my employer