Question 142: (a) In compliance with 10 CFR 20.2104 (a)
(2), what constitutes an acceptable attempt to obtain a
record of the lifetime dose for a worker? b) Since there
are no limits for lifetime doses (other than planned
special exposures), and lifetime dose reports to workers
are not required, why must licensees go to the expense of
obtaining and recording these doses?
Answer: (a) The licensee should request this information
from the worker. Alternatively, the licensee also may
request this information from the worker's most recent
employer for work involving radiation exposure or the
worker's current employer if the individual is not employed
by the licensee. If this request is denied, the licensee
need make no further efforts to obtain the information;
however, the individual will not be available for a planned
special exposure.
b) As explained in the Statement of Considerations (56 FR
23383, 23384) the requirement to attempt to obtain the
records of lifetime cumulative doses follows one of the
provisions of the guidance to Federal agencies on
occupational radiation protection. Also, as stated in
SECY-88-315 (available in the NRC Public Document Room),
the recordkeeping and reporting requirements of the revised
Part 20 are consistent with implementing an NRC staff
recommendation to establish a registry of radiation workers
and their radiation doses. Such a registry will be of
value in analyzing doses received by workers at several
sites during the year, in tracking exposure trends, and
will facilitate epidemiological studies of potential
radiation-induced health effects. (Reference: 10 CFR
20.2104).