Health Physics Questions and Answers - Question 41

Question 41: Licensee A questions a new employee about outside employment. The employee states that he is only working at that facility. After 3 months, the employee starts working, in the evenings, at another licensed facility (Licensee B). The employee does not tell A about B; therefore, Licensee A does not take the exposure received by the employee at facility B into account when he calculates the employees annual total effective dose equivalent (TEDE). Will Licensee A be in noncompliance for not knowing about the dose received by the employee at Licensee B? If licensee A was made aware of the exposure at Licensee B after-the-fact, must Licensee A go back and account for this exposure when calculating TEDE? If Licensee A finds out about the worker's exposure at Licensee B after the year's end, and if the sum of the exposures exceeded the annual limit, is Licensee A obligated to record and report the overexposure and deduct it from the 25 rem lifetime PSE limit?

Answer: In order to meet the requirements of 10 CFR 20.1201 (f), the licensee must establish some means to have each employee inform the licensee when that employee is receiving occupational dose from sources outside the licensee's control. It is not sufficient merely to ask each employee once (as in the example), with no continuing provision for employee notification. Assuming that Licensee A made no provision for learning of the new employees subsequent concurrent employment in other jobs that resulted in occupational dose, Licensee A would be in noncompliance for not determining the dose received on the job at Licensee B. If Licensee A was made aware of the exposure at Licensee B after-the-fact, Licensee A must go back and account for this exposure when calculating TEDE. If Licensee A finds out about the worker's exposure at Licensee B after year's end, and if the sum of the exposures exceeded the annual limit, Licensee A is obligated to record and report the overexposure and to deduct it from the 25 rem lifetime PSE limit. Although the question and preceding answer are provided in terms of Licensee A's responsibilities with respect to doses received at Licensee B's facility, Licensee B has the same responsibilities with respect to doses received at licensee A's facility.

(Reference: 10 CFR 20.1201)