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Question 41: Licensee A questions a new employee about
outside employment. The employee states that he is only
working at that facility. After 3 months, the employee
starts working, in the evenings, at another licensed
facility (Licensee B). The employee does not tell A about
B; therefore, Licensee A does not take the exposure
received by the employee at facility B into account when he
calculates the employees annual total effective dose
equivalent (TEDE). Will Licensee A be in noncompliance for
not knowing about the dose received by the employee at
Licensee B? If licensee A was made aware of the exposure
at Licensee B after-the-fact, must Licensee A go back and
account for this exposure when calculating TEDE? If
Licensee A finds out about the worker's exposure at
Licensee B after the year's end, and if the sum of the
exposures exceeded the annual limit, is Licensee A
obligated to record and report the overexposure and deduct
it from the 25 rem lifetime PSE limit?
Answer: In order to meet the requirements of 10 CFR
20.1201 (f), the licensee must establish some means to have
each employee inform the licensee when that employee is
receiving occupational dose from sources outside the
licensee's control. It is not sufficient merely to ask
each employee once (as in the example), with no continuing
provision for employee notification. Assuming that
Licensee A made no provision for learning of the new
employees subsequent concurrent employment in other jobs
that resulted in occupational dose, Licensee A would be in
noncompliance for not determining the dose received on the
job at Licensee B. If Licensee A was made aware of the
exposure at Licensee B after-the-fact, Licensee A must go
back and account for this exposure when calculating TEDE.
If Licensee A finds out about the worker's exposure at
Licensee B after year's end, and if the sum of the
exposures exceeded the annual limit, Licensee A is
obligated to record and report the overexposure and to
deduct it from the 25 rem lifetime PSE limit. Although the
question and preceding answer are provided in terms of
Licensee A's responsibilities with respect to doses
received at Licensee B's facility, Licensee B has the same
responsibilities with respect to doses received at licensee
A's facility. (Reference: 10 CFR 20.1201)