United States Nuclear Regulatory Commission - Protecting People and the Environment

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)

Page Last Reviewed/Updated Thursday, March 29, 2012