Section III - Discussion III. DISCUSSION It is DOE policy to generate and maintain complete and accurate radiation protection records of individuals who work in or visit DOE facilities, to use these records to protect individuals from unnecessary radiation exposure, and to make these records available as prescribed by the applicable DOE Orders and the Privacy Act. Other uses of these records should include 1) evaluation of the effectiveness of the radiation protection program, 2) demon- stration of compliance with regulations and requirements, and 3) defense of the radiation protection program against unwarranted litigation. All records prescribed in this IG should be readily retrievable and auditable. In general, requirements contained in 10 CFR 835 and DOE Orders establish a baseline level of intended program performance, while the requirements in the RCM set forth a standard of excellence. This guide identifies if and how the referenced requirements differ for a specific provision of the guide and, where appropriate, how the suggested actions in the provisions are applicable to the related requirements. A functional and effective occupational radiation protection record-keeping and reporting program is required at DOE facilities that use radioactive materials or radiation-generating machines. This IG defines and provides instructions for imple- menting a program that will meet DOE regulatory requirements for the generation, administration, and retention of occupa- tional radiation protection records, reports, and supporting documentation for DOE employees, DOE contractor and subcontractor employees, and visitors to DOE facilities. The basic requirements for conducting an effective occupational radiation protection record-keeping and reporting program are provided, based on requirements consolidated from various DOE Orders and other regulatory guidelines discussed here. The RCM contains practices for the conduct of radiological control activities. Chapter 7 of the RCM contains practices for radiological records and reports. Other chapters may also contain practices that apply to radiation protection records and reports. The RCM is invoked by DOE Order 5480.11, as amended. Paragraph 8.a of DOE Notice N 5480.6, "Radiological Controls" (DOE, 1992b) states that, to the extent that there is a conflict between a provision of the RCM and a provision of a specific set of DOE Orders listed in the RCM, the provision of the RCM shall supersede the provision of those DOE Orders. 10 CFR 835 contains rules concerning occupational radiation protection record-keeping and reporting practices. DOE Order 5484.1, "Environmental Protection, Safety, and Health Protection Information Reporting Requirements" (DOE, 1987), DOE Order 5000.3B, "Occurrence Reporting and Processing of Operations Information" (DOE, 1993c), and DOE Order 1324.2A, "Records Disposition" (DOE, 1988), also provide record-keeping and reporting requirements. In addition to the DOE Orders, 10 CFR 1008, "Records Maintained on Individuals (Privacy Act)" (DOE, 1980) contains rules that affect the handling of radiation protection records. Relevant sections of American National Standards Institute (ANSI) Standard N13.6, "American National Standard Practice for Radiation Exposure Records Systems" (ANSI, 1989), that are referenced in DOE 5480.11 are 1) Section 4, "Records Related to an Individual," 2) Section 5, "Records Related to the Radiation Status of a Work Area," and 3) Section 6, "Records Related to the Radiation Protection Program." This IG provides information on the necessary types of records, reports, and methods for generating and maintaining them; records retention schedules; and "Privacy Act and Freedom of Information Act" (FOIA, 1986) considerations. The methods that are acceptable to DOE for implementation of requirements for occupational radiation protection record-keeping and reporting programs are also described in the guide.