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

[BLHamrick@aol.com]

In a message dated 10/23/1999 8:29:41 AM Pacific Daylight Time, 
sandyfl@earthlink.net writes:

<< Barbara, I agree that this is primarily a Privacy Act issue. However, 
 the regulations do state that when an individual requires monitoring, 
 that the facility have a signed statement from the individual 
 validating the dose information. The individual has the right not to 
 sign the statement, and therefore, the record is not made available. 
 In that case, I am asking what the regulator's position would be if a 
 hospital (let's say a nuclear medicine facility & a radiology 
 department) has a document from me, or another commercial 
 processor, stating the individuals working in each department, and 
 cumulative dose for each worker, that derives from several other 
 facilities. What would their statement be at that time? >>

Correct me if I'm wrong, but I think you're referring to 10 CFR 20.2104.  
This section requires, in part, that dose information be obtained for the 
current year, and that once obtained from sources listed in 20.2104(c), the 
information be recorded on a Form 4 (or equivalent), and signed by the 
individual.  I guess, as a regulator, I would want to talk to the individual 
and find out why they refused to sign the dose record...Maybe they believe it 
does not record their true dose for some reason.

I have never actually run across this situation, so I would discuss this with 
my management first, but off the top of my head, if the individual refuses to 
validate the information on the Form 4 (or equivalent) as required in 
20.2104(d), then I think the licensee would be forced into the alternative 
route discussed in 20.2104(e) - i.e., reducing the available dose for the 
year by 1.25 rem per quarter for each quarter for which the dose was 
unavailable (or unvalidated).

Barbara L. Hamrick
BLHamrick@aol.com
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