Issue:

Introduction:

Discussion:

Individuals who are terminating their employment may require a current radiation dose report for the current year prior to beginning work at a new facility. Title 10 CFR 835.801(b) requires that, if requested by an individual terminating employment, a dose report be provided to that individual as soon as the data are available, but no later than 90 days after termination. In addition, the rule requires, if requested by an individual terminating employment, a written estimate of the radiation dose received by that employee be provided at the time of termination, based on available information.

All termination radiation dose reports must contain the information required under 10 CFR 835.702(c), as required by 10 CFR 835.801(a). Termination reports may also serve as the annual report for these individuals; however, written estimates of the radiation dose received may not. The final termination report for individuals who terminate employment at a site or facility more than once in a year should contain all the monitoring information for that year if that report is to also serve as the annual report. Otherwise; a separate annual report must be provided summarizing the individual's monitoring results at the site or facility for the entire year. 

Technical Position:

• 10 CFR 835 requires that a termination dose report be provided only upon request of the individual terminating employment. This requirement includes visiting scientists, technicians, and specialists performing radiological work at a facility and then returning to their present job location, regardless of the duration. Visiting scientists and specialists performing radiological work are considered general employees as defined in 10 CFR 835.2(a). As such, these individuals are subject to the 5 rem Total Effective Dose Equivalent (TEDE) limit for general employees rather than the 100 mrem TEDE member of the public limit. Accordingly, visiting scientists and specialists classified as general employees and monitored in accordance with 10 CFR 835.402 must receive a termination dose report as required by 10 CFR 835, if requested by the individual.<1>
• The rule uses the phrase "Upon the request..." in 10 CFR 835.801(b) to specify whether the termination report must be provided to an individual terminating employment. If the request has been made, the dose report is required as soon as the data are available, but not later than 90 days after termination. The rule allows for written estimates to be provided at the time of termination, if requested by the individual. If the individual does request a termination report, the request must be made on or before the individual's last day of employment. Otherwise, the request for dose information would fall under 10 CFR 835.801(d), which specifies no time limit associated with the response, but should be provided as soon as reasonably achievable after the request is made.
• The rule does not specify details regarding an individual's request for exposure information. No guidance is given in the Occupational Radiation Protection Record-Keeping and Reporting Implementation Guide (IG) on how the request is required to be made or to whom the request must be made. Nor does the IG recommend whether the request should be documented or not (to show compliance with the rule). Each facility's radiation protection program should document how the request should be made and to whom the request should be made. This topic should also be addressed in the appropriate radiological training courses.

References:

1. 10 CFR 835, Occupational Radiation Protection, U.S. Department of Energy, December 14, 1993. 
2. DOE/EH-0256T, DOE Radiological Control Manual, Revision 1, U.S. Department of Energy, April 1994. 
3. G-10 CFR 835/H1, Occupational Radiation Protection Record-Keeping and Reporting Implementation Guide, Revision 1, U.S. Department of Energy, November 1994.