Question 441: If the declared pregnant woman's estimated
date of conception encompasses a previous period of
employment at another licensee's facility, what assumptions
should be made by the current licensee for compliance
purposes under each of the following conditions?
a. Until records are received from the previous licensee;
b. If previous monitoring records are incomplete or
otherwise unavailable; and
c. If monitoring by the previous licensee of the woman's
deep dose equivalent and/or the committed effective dose
equivalent was not required, and therefore dose records
were not maintained, but the woman is likely to have
received dose due to the nature of her employment at the
previous licensee's facility.
Answer: See the answer to the related Question 406 under
the heading for Regulatory Guide 8.36.
a) As provided in 10 CFR 20.2104 (c), the licensee may
accept, as a record of the prior dose to the embryo / fetus,
a signed statement from the declared pregnant woman.
("Records from the previous licensee" are not required;
however, as indicated in the answer to Question 371, it is
considered good health physics practice to verify the
information on prior exposure provided by the individual.)
b) The answer to this question is the same as the answer
to part (a) of the question if the woman can provide the
information on the prior dose to the embryo / fetus; that is,
the licensee may accept, as a record of the prior dose to
the embryo / fetus, a signed statement from the woman. If
the woman cannot provide this information, the licensee
should [as indicated in the answer to Question 406 (b)]
make an effort to make a reasonable estimate of the dose
using other information that the woman and her previous
employer have concerning her exposure.
c) As indicated in the answer to part (b) of the question
and in the answer to Question 406, the licensee should make
an effort to make a reasonable estimate of the dose using
other information that the woman and her previous employer
have concerning her exposure. (References: 10 CFR
20.1208, 10 CFR 20.2104)