Health Physics Questions and Answers - Question 408

Question 408:


10 CFR 20.2104 states that for each individual for whom monitoring is required, the licensee must: 1.) Determine the occupational radiation dose for the current year; and 2.) Attempt to obtain the records of lifetime cumulative occupational radiation dose. "Records of lifetime cumulative occupational radiation dose" refers to occupational dose records prior to the current year. These records are only used when implementing the planned special exposure option. Some licensees may use prior year's TEDE to control an individual's lifetime dose in compliance with NCRP-91 recommendations or average annual exposure in compliance with ICRP-60 recommendations. However, other prior year's dose quantities such as shallow dose equivalent (SDE) and lens (eye) dose equivalent (LDE) are not useful to licensees and provide no additional protection to individuals. Therefore, it was reasonable and compliant to obtain only TEDE for prior years. Can a licensee seek only to obtain the TEDE occupational dose quantity for prior years to comply with the 20.2104 (a) (2) requirement to "attempt to obtain the records of lifetime cumulative occupational radiation dose"?

Answer: Yes, provided the licensee does not intend to authorize planned special exposures for the individuals for whom the licensee attempts to obtain only the TEDE. For planned special exposures, the provisions of 10 CFR 20.1206 (e) that limit "lifetime" exposures apply to all occupational doses having annual limits in 10 CFR 20.1201 (a) (TEDE, organ dose, eye dose, skin dose and extremity dose), not just the TEDE. The reasons for this requirement other than for use in cases of planned special exposures are given in the answer to Question 142 (b).

(Reference: 10 CFR 20.2104)

Page Last Reviewed/Updated Friday, December 01, 2017