Health Physics Questions and Answers - Question 64

Question 64: The following question relates to the requirements of 10 CFR 20.2104 (a) (2), 10 CFR 20.2104 (c), and 20.2104 (d) concerning records of lifetime cumulative occupational dose. Assuming that (1) the licensee has obtained, by electronic media, a printed report (or reports) containing the Form 4 information on an individual's lifetime cumulative dose, (2) the individual who received the dose signed Form 4, or equivalent, in accordance with 10 CFR 20.2104 (d), and (3) there is no other signature attesting to the authenticity of the Form 4 record. Is the licensee in compliance with the requirements in 10 CFR 20.2104 concerning records of lifetime cumulative occupational dose?

Answer: Yes. As stated in Regulatory Guide 8.7, Section C.1.3, to demonstrate compliance with the requirement of 10 CFR 20.2104 (a) (2) (to attempt to obtain the records of lifetime cumulative occupational radiation dose), the individual to be monitored may provide a written estimate of the cumulative lifetime dose or an up-to-date NRC Form 4 signed by the individual. This information does not need to be verified so long as the individual does not participate in a planned special exposure. However, in the unlikely event that it was the individual who provided the licensee with the report by electronic media, Regulatory Guide 8.7, Section C.1.3, also states that "Although not required by the regulations, it is considered good health physics practice to verify the information provided by the individual."

(Reference: 10 CFR 20.2104)