exposure records - summary of comments

[Les Slaback <lester.slaback@nist.gov>]

I posed the question of reasons beyond litigation to retain exposure
records, and requested comments be sent to me.  Most were, and I summarize
them here for your information, albeit
greated abbreviated. Any errors created in context are strictly mine.


"    Will there ever be a "lifetime dose" that the NRC will add to their
regulations?  If so will records of exposure maintained forever be
needed to comply with this?  - steve hand"
***In other words, should we retain them because the rules might change?
And Les Aldrich noted that "DOE facilities do have the
RadCon Manual "Lifetime Control Limit" of N rem (where N is the age of
the person in years)."  Hence the NCRP lifetime dose control already exists
in one regulated arena.
And The Sandy said, while agreeing that litigation is probably the sole
reason for
retention, ...
"In my opinion, regardless of the litigation, it is still prudent to keep 
the records. One can't look into the future and see what may be 
ahead of us."


In the context of a program with mostly low doses .....
"At our institution about 95 % of those monitored receive NO measurable dose.
  <snip>
In my mind the threat of litigation (never exercised to my knowledge) is
probably the ONLY reason we keep all these records.

I believe it would be prudent to keep a more simple record for each employee.
  <snip>
After all, monitoring individual dose is just a type of "survey."  We only
retain survey records of posted restricted areas for 3 years and then they
(the
documents) are destroyed.  However, a SUMMARY of all surveys, is retrievable
through our computerized database.   -R. Zoon"

A number of others noted that litigation fears makes pack rats of us all.

And noted directly to RADSAFE were the basic NRC retention requirement, and
the
need for a record if a Planned Special Exposure was needed.  20.1206 does
require
a history as part of the PSE authorization, but IMHO past risk history is a
moot
issue when contemplating taking an added future risk. The primary and
dominant issue
should be minimizing that potential future risk. Nonetheless these two
regulatory requirements currently exist.  But one can always hope that the
regulators will trim the rules of such nonsensical requirements.  :-)

And lastly, epidemiology was listed (both as a reason and a non-reason).

Not identified is the basic rad.prot programmatic need to maintain enough
history
so that the effectiveness of the program can be assessed.

Sorry, more opinion leaked into my summary.  I do not intend to start
another thread.


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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