With privacy being a concern, must we list employees birthdates and social security numbers on our radiation dosimetry reports?
The Ionizing Radiation Rules require, in Rule 245(1), that records showing the radiation doses of all individuals for whom personnel monitoring is required be maintained. Those records must include the name, social security number, and the date of birth of each individual. The obvious reason for this requirement is that an employer, over its history, may have more than one employee with the same name. However, personal privacy has become a growing concern for our society. It is possible to honor the desire for privacy by maintaining a separate record that would include the individual’s social security number, the date of birth, and a unique Employer Assigned Identification Number. This unique number may be provided to the dosimetry provider as an alternative to the social security number. The facility must maintain in its records the dosimetry reports, provided by the dosimetry provider, and the record that documents the unique, Employer Assigned Identification Number of the employees
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