Question 401: NRC Form 5 (Item No. 20) provides for the
signature of the licensee's authorized representative
responsible for the data and is not noted as "optional" as
is the licensee signature block on NRC Form 4. Appendix A
of Regulatory Guide 8.7, Rev. 1, "Instructions for
Recording and Reporting Occupational Radiation Exposure
Data," provides for the licensee to sign the transmittal
letter for electronic transmission of exposure data to the
NRC and thereby certify the database. If a letter
certifying the database is maintained on file, can the
licensee so note NRC Form 5's which are generated from the
database, e.g., "signature on file," rather than signing
each individual NRC Form?" In particular, this would
facilitate the providing of individual exposure reports
annually to each worker, as required by 10 CFR Part 19.
Answer: Yes, if the exposure data are reported to the NRC
by electronic transmission, the Form 5 exposure report
prepared from the data base and provided to the worker need
not be signed ("signature on file" is acceptable). However,
if the exposure data are provided to the NRC on Form 5,
rather than by electronic transmission, the form must be
signed. As noted in the question, the signature block on
Form 5 is not optional. (References: 10 CFR 20.2106, 10
CFR 20.2206, Regulatory Guide 8.7, Rev. 1).