Health Physics Questions and Answers - Question 436

Question 436: Licensees are required to "reduce the dose that an individual may be allowed to receive in the current year by the amount of occupational dose received while employed by any other person." How should this provision be applied to dose categories required to be monitored by the current licensee, for which the individual's dose report (e.g., NRC Form 5) from previous employment during the current year at another licensee's facility indicates "NR" (not required), "ND" (not detectable), or is left blank? May the dose in categories denoted on the dose record as "NR", "ND", or left blank be assumed to be zero, and therefore no reduction be made to the dose that the individual may be allowed to receive in the current year?

Answer: Yes, for cases in which "NR" or "ND" have been recorded. However, if there is no recorded dose for a dose category and no reason for this omission has been provided (i.e., "NR" or "ND" have not been entered), the licensee should determine if the dose value has been omitted erroneously before assuming it to be zero (e.g., by checking with the licensee that provided the Form 5 with a dose category left blank). If the licensee cannot determine why there is no recorded dose for a dose category, the licensee has been unable to obtain a complete record of the individual's dose history for that dose category and the individual's exposure must be limited in accordance with 10 CFR 20.2104 (e) (1).

(Reference: 10 CFR 20.1201, 10 CFR 20.2104, Regulatory Guide 8.7, Rev. 1)