Re: How long do we keep records

["F Dawson D Def H&S" <modsafety@gtnet.gov.uk>]

In the UK we too have statutory duties to keep radiation dose records for
personnel, radiation surveys, accidents for various periods of time up to 50
years

My recent experience with a number of civil court cases has persuaded me
that regardless of these regulatory duties that records should be kept
indefinitely. This also conforms with the media's and publics expectation.

We have just invested million pounds in a computer system to scan and index
our old paper records going back as far as the 1950's. These include things
such as entry logs, training records etc.

I suspect that whilst you may comply with the regulations you may still be
open to civil litigation.

Mr FWP Dawson, Head of Health Physics
Directorate of Defence Health & Safety
Ministry of Defence, Aquila, Golf Road,
Bromley, Kent. BR1 2JB
England
Phone (44) 181 285 7650
Fax  (44) 181 285 7699

The views expressed  are my own and not necessarily those of my employer

-----Original Message-----
From: Denis J. Rinkacs, Jr. <dr4i@MAIL1.andrew.cmu.edu>
To: Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
Date: 25 June 1998 04:54
Subject: How long do we keep records


>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
>
>
>
>
>