Health Physics Questions and Answers - Question 401
Question 401: NRC Form 5 (Item No. 20) provides for the signature of the licensee's authorized representative responsible for the data and is not noted as "optional" as is the licensee signature block on NRC Form 4. Appendix A of Regulatory Guide 8.7, Rev. 1, "Instructions for Recording and Reporting Occupational Radiation Exposure Data," provides for the licensee to sign the transmittal letter for electronic transmission of exposure data to the NRC and thereby certify the database. If a letter certifying the database is maintained on file, can the licensee so note NRC Form 5's which are generated from the database, e.g., "signature on file," rather than signing each individual NRC Form? "In particular, this would facilitate the providing of individual exposure reports annually to each worker, as required by 10 CFR Part 19.
Answer: Yes, if the exposure data are reported to the NRC by electronic transmission, the Form 5 exposure report prepared from the data base and provided to the worker need not be signed ("signature on file" is acceptable). However, if the exposure data are provided to the NRC on Form 5, rather than by electronic transmission, the form must be signed.As noted in the question, the signature block on Form 5 is not optional.
(References: 10 CFR 20.2106, 10 CFR 20.2206, Regulatory Guide 8.7, Rev. 1)