Answer to Question #461 Submitted to "Ask the Experts"

Category: Policy, Guidelines, and Regulations — Guidance Documents

The following question was answered by an expert in the appropriate field:

Is there a regulation that specifically addresses dosimetry badging employees who work for a single vendor and perform work in rad areas at different sites? Basically, can an employer require the employee to wear a single dosimetry badge at all sites or will each site do its own badging? If each site does its own badging can the employee also use the employer's badge? If so, how is double dose assessing prevented? Thanks

State and federal regulations require that licensees and registrants assure that their employees do not exceed the annual occupational total effective dose equivalent (TEDE). There are several situations and methods by which this can be accomplished:

For licensees and registrants whose employees work at temporary job sites, but the work is done under the single license or registration, the employer should require a single badge to be worn for all work performed.

For vendors, such as Rent-a-Tech services, in which the employee is actually working under the provisions of separate licenses for the facilities in which they are working, the service can provide a single badge to show all occupational dose, or, if they are provided a badge by each licensee where they work, they must share the information from their dosimetry history in order for the new employer to assure that the total dose has not exceeded the limit for the year. If each site does its own badging, the rules do not prohibit the use of the employer's badge as well. It must be made clear to the dosimetry record keepers, however, that the badges were being worn at the same time, not in sequence in order that double doses are not assessed. The methodology of meeting the regulations should be worked out between the tech rental agency and the hiring facilities.

An example of #1 is the consulting physicist who works on x-ray and teletherapy equipment at several locations in the course of work, or industrial radiography firms that work at temporary job sites. Examples of #2 are techs who work for a company that provides temporary employees to facilities, where the facility is a licensee that must assure that occupational dose limits are met.

Ruth McBurney, CHP

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