Question 436: Licensees are required to "reduce the dose
that an individual may be allowed to receive in the current
year by the amount of occupational dose received while
employed by any other person." How should this provision
be applied to dose categories required to be monitored by
the current licensee, for which the individual's dose
report (e.g., NRC Form 5) from previous employment during
the current year at another licensee's facility indicates
"NR" (not required), "ND" (not detectable), or is left
blank? May the dose in categories denoted on the dose
record as "NR", "ND", or left blank be assumed to be zero,
and therefore no reduction be made to the dose that the
individual may be allowed to receive in the current year?
Answer: Yes, for cases in which "NR" or "ND" have been
recorded. However, if there is no recorded dose for a
dose category and no reason for this omission has been
provided (i.e., "NR" or "ND" have not been entered), the
licensee should determine if the dose value has been
omitted erroneously before assuming it to be zero (e.g., by
checking with the licensee that provided the Form 5 with a
dose category left blank). If the licensee cannot
determine why there is no recorded dose for a dose
category, the licensee has been unable to obtain a complete
record of the individual's dose history for that dose
category and the individual's exposure must be limited in
accordance with 10 CFR 20.2104 (e) (1). (Reference: 10
CFR 20.1201, 10 CFR 20.2104, Regulatory Guide 8.7, Rev. 1).