Re: How long do we keep records

["Harald Weiß, Kiel" <weiss@ki.comcity.de>]

Denis J. Rinkacs, Jr. schrieb:
>
> 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.
> 

The same problem can arise elsewhere and we've been thinking of it, too.
We have come to the conclusion that both requirements must be fulfilled.
BUT, when you have given back your license, there is no-one left to be
responsible for keeping the records. So if your company doesn't
voluntarily take the liability to archive them for the rest of those 30
years, you would have to hand them (the records, of course) out to the
authorities so that they care for it.

No legal stuff, no court acts, just the thoughts we developed when we
had to think on it as advisors to german authorities. And the result
doesn't necessarily coincide with the opinions of my employer or his
customers.
--
Harald Weiss				weiss@ki.comcity.de
Preetzer Strasse 263			Tel. +49-431-78 59 659
D-24147 Kiel				Fax. +49-431-78 59 658
..