U.S. Nuclear Regulatory Commission
Question 441: If the declared pregnant woman's estimated date of conception encompasses a previous period of employment at another licensee's facility, what assumptions should be made by the current licensee for compliance purposes under each of the following conditions?
a. Until records are received from the previous licensee;
b. If previous monitoring records are incomplete or otherwise unavailable; and
c. If monitoring by the previous licensee of the woman's deep dose equivalent and/or the committed effective dose equivalent was not required, and therefore dose records were not maintained, but the woman is likely to have received dose due to the nature of her employment at the previous licensee's facility.
Answer: See the answer to the related Question 406 under the heading for Regulatory Guide 8.36.
a) As provided in 10 CFR 20.2104 (c), the licensee may accept, as a record of the prior dose to the embryo / fetus, a signed statement from the declared pregnant woman. ("Records from the previous licensee" are not required; however, as indicated in the answer to Question 371, it is considered good health physics practice to verify the information on prior exposure provided by the individual.)
b) The answer to this question is the same as the answer to part (a) of the question if the woman can provide the information on the prior dose to the embryo / fetus; that is, the licensee may accept, as a record of the prior dose to the embryo / fetus, a signed statement from the woman. If the woman cannot provide this information, the licensee should [as indicated in the answer to Question 406 (b)] make an effort to make a reasonable estimate of the dose using other information that the woman and her previous employer have concerning her exposure.
c) As indicated in the answer to part (b) of the question and in the answer to Question 406, the licensee should make an effort to make a reasonable estimate of the dose using other information that the woman and her previous employer have concerning her exposure.
(References: 10 CFR 20.1208, 10 CFR 20.2104)