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Question 51: Do 10 CFR 20.2104 (a), 10 CFR 20.2104 (d) and
Footnote 4 to 20.2104 (d) mean that a licensee must
"backfit" effective dose equivalents (EDE) for individuals
who were occupationally exposed before implementation of
the revised Part 20?
Answer: No. Such backfitting is not required. However,
licensees may, if they so desire, make estimates of the EDE
and committed EDE based on the occupational dose records
available for this period. (References: 10 CFR 20.2104
(a), 10 CFR 20.2104 (d), 10 CFR 20.2104 (d) Footnote 4 )