RE: Personnel exposure records

["CHASE,VINCE AD BIPUS" <vchase@bi-pharm.com>]

NRC regulations state that all dosimetry records (internal, external,
skin, etc) must be kept until .."the Commission terminates each
pertinent license requiring the record." (20,2107(b).  I assume that
most Agreement States have the same provision since they cannot be less
restrictive than the NRC.

I have seen some buzz on the SAFETY listserver from upper managers who
are IH types who worry about long term litigation at facilities that
have multiple licenses.  Their worry seems to be that destroying dose
records for a particular license while other licenses are in force at
the same site could lead to very complicated legal entanglements.
However,  I have never heard of any problems of this nature.  Perhaps
someone else has.

Hope this helps.

Regards,
Vince Chase
Radiation Safety Officer
vchase@bi-pharm.com
Boehringer Ingelheim Pharmaceuticals
The opinions expressed here are those
of the author and do not represent the
opinions, policies or practices of
Boehringer Ingelheim Pharmaceuticals.

-----Original Message-----
From:	Les Slaback [SMTP:lester.slaback@nist.gov]
Sent:	Thursday, July 30, 1998 11:11 AM
To:	Multiple recipients of list
Subject:	Personnel exposure records

Is there any reason, other than for litigation, to retain exposure
records
many years after the persons exployment or exposure?
I discount epidemiology since current practices and regulatory
requirements
(i.e., point of highest exposure) bias the data upwards by significant
and
unknown and undocumented factors.  And the demise of 5(N-18) has removed
the rad.protection programmatic reason.

If in fact litigation is the only reason then perhaps HP staffs should
have
a legal tech for maintaining such records.  And if so perhaps NRC should
make the record retention requirements optional beyond some minimal
period.

This question is prompted by a proposed HPSSC std for rad.prot records,
which includes as part of its purpose litigation protection.

Please send responses directly to me for summary unless you desire to
stir
up the troops.

Disclaimer:  the above are the personal musings of the author, and do
not
represent any past, present, or future position of NIST, the U.S.
government,
or anyone else who might think that they are in a position of authority.

Lester Slaback, Jr.  [Lester.Slaback@NIST.GOV] 
NBSR Health Physics 
Center for Neutron Research 
NIST 
Gaithersburg, MD  20899 
301 975-5810
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