Re: Privacy Act - Providing dose of record to other facilities

[William V Lipton <liptonw@dteenergy.com>]

I seem to be missing something, here.  While the dosimetry processor can
determine TLD readings, the licensee must determine the dose received.  The
licensee is responsible for determining dosimetry placement, assuring that
workers properly use the dosimetry, and correcting TLD readings when
appropriate, based on factors such as correcting for inappropriate placement
or use, substituting secondary dosimetry results if, in the licensees
judgment, the TLD reading is not valid, and adding CEDE when appropriate.

How can the dosimetry processor do this?

Maybe, I'm misinterpreting your question and that the dosimetry processor is
also contracted to maintain dosimetry records for a licensee.  In that case,
however, the licensee must still determine the dose.  It seems to me that a
licensee who rubber stamps a processor's readings without an evaluation
process is not in accordance with 10CFR20.

The opinions expressed are strictly mine.
It's not about dose, it's about trust.

Bill Lipton
liptonw@dteenergy.com

Sandy Perle wrote:

> I have a specific question regarding providing dose of record
> information from one facility to another facility, when the
> individual works at more than one facility (different employers). In
> the commercial world, I have to face this for numerous clients. I
> have been requiring each facility, and the individual, to sign a
> waiver form, allowing us to provide all the facility dose received
> from all other facilities. This is what was required when I worked in
> the power reactor world. No dose was released to another facility
> without the signed consent form. I have been told by many clients
> when they were told that this is my requirement, that I am the only
> commercial entity requiring this waiver and consent form. Therefore,
> I would appreciate feedback from both state and NRC staff whether or
> not releasing dose information from many employers to another
> employer is permitted without the signed waiver and consent form. I
> have provided section from 10CFR20.2104 and 20.2106 (state
> regulations generally have the same requirements). Let me also add
> that the report I send a client does not breakdown the dose from each
> facility, nor does it name each facility. I provide the cumulative
> annual dose to date for all locations. I still consider this to come
> under the Privacy Act, since the individual has not signed an
> informed consent that their dose information be released to one or
> more of their current employers.
>
> Please provide your comments to be directly if you prefer. If there
> is consensus that the waiver and signed consent form is not needed, I
> will revise my directive/
>
> Thank you in advance:
>
> BASIS FOR SIGNED CONSENT:
>
> § 20.2104 Determination of prior occupational dose.
>
> (a) For each individual who is likely to receive, in a year, an
> occupational dose requiring monitoring pursuant to § 20.1502, the
> licensee shall--
>
> (d) The licensee shall record the exposure history, as required by
> paragraph (a) of this section, on NRC Form 4, or other clear and
> legible record, of all the information required by NRC Form 4. The
> form or record must show each period in which the individual received
> occupational exposure to radiation or radioactive material and must
> be signed by the individual who received the exposure. For each
> period for which the licensee obtains reports, the licensee shall use
> the dose shown in the report in preparing NRC Form 4......
>
> § 20.2106 Records of individual monitoring results.
>
> (d) Privacy protection. The records required under this section
> should be protected from public disclosure because of their personal
> privacy nature. These records are protected by most State privacy
> laws and, when transferred to the NRC, are protected by the Privacy
> Act of 1974, Pub.L. 93-579, 5 U.S.C. 552a, and the Commission's
> regulations in 10 CFR part 9.
>
> Sandy Perle
> E-Mail: sandyfl@earthlink.net
> Personal Website: http://www.geocities.com/capecanaveral/1205
>
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