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The Columbia University Medical Center Radiation Protection
Policy For Pregnant Workers shall be implemented as follows(6):
1. Method of instruction to workers
As part of their initial employment(7), all radiation
workers are required to receive from the Radiation Safety
Office, instructions in radiation protection. These instructions
may be given at a new employee orientation or at a scheduled
radiation safety lecture for new employees. These instructions
should include; the effects of radiation to the embryo/fetus, a
statement of the special limit for protection of the
embryo/fetus of a declared pregnant woman, the responsibility of
the pregnant woman to declare her condition to the Radiation
Safety Office and the importance of her doing so. A copy of this
policy should be distributed to each new radiation worker at
their initial radiation safety orientation.
Instruction in the special limit for protection of the
embryo/fetus of a declared pregnant woman and the CUMC pregnancy
policy should be included in all annual refresher training.
Copies of this policy, the U.S.N.R.C. Regulatory Guide 8.13,
Instruction Concerning Prenatal Radiation Exposure, and the
Declaration of Pregnancy Form shall be made available at all
refresher training sessions and in the Radiation Safety Office.
At the time of her Declaration of Pregnancy, the declared
pregnant woman will receive individual counseling from a Health
Physicist or Medical Physicist on the staff of the Radiation
Safety Office.
2. Responsibility of workers
Federal statute(8) mandates that; "It is the
fundamental responsibility of the pregnant worker to decide when
or whether she will formally declare her condition to her
employer." It is the policy of the Medical Center that formal
declaration is defined as filing a completed, signed and dated
Declaration of Pregnancy form with the Radiation Safety Office.
A copy of the Declaration of Pregnancy Form is attached as
APPENDIX A. If she chooses not to declare her pregnancy, the
Radiation Safety Office will continue to ensure that she
receives all normal occupational protections - the annual
occupational dose limit of 50 mSv (5.0 rem)(9) and
all ALARA(10) requirements will be in effect. All
rights of declaration rest with the pregnant woman. The
declaration of pregnancy may withdrawn at any time by a signed,
dated, written statement of withdrawal filed with the Radiation
Safety Office.
In addition, all radiation workers have an individual
responsibility to comply with RCNY Article 175 requirements. The
Rules of the City of New York, Article 175(11) states
that "the supervised individual shall follow the instructions of
the supervising authorized user; follow the procedures
established by the radiation safety officer; and comply with
this Code and with the license conditions with respect to the
use of radioactive material."
3. Regarding work assignments for
pregnant workers
In order to insure that the dose to an embryo/fetus(12)
during the entire pregnancy, due to occupational exposure of a
declared pregnant woman, does not exceed 5 mSv (0.5 rem), the
Radiation Safety Office shall review the exposure history and
the present job duties of the declared pregnant woman and
require the adjustment in working conditions so as to avoid a
monthly exposure of more than 0.5 mSv (0.05 rem) to a declared
pregnant woman(13). This adjustment would range from
requiring the wearing of a personnel radiation dosimeter as an
assigned fetal monitor to a prohibition of participation in
certain procedures.
If, by the time the pregnant worker declares pregnancy to the
Radiation Safety Office, the dose to the embryo/fetus has
exceeded 4.5 mSv (0.45 rem), the Radiation Safety Office shall
ensure that additional occupational dose to the embryo/fetus
does not exceed 0.5 mSv (0.05) rem during the remainder of the
pregnancy(14). The radiation dose to the embryo/fetus
is defined as the sum of the deep dose equivalent to the
declared pregnant woman from external sources of radiation, such
as X-rays and gamma-rays and the internal dose to the
embryo/fetus from the uptake of radionuclides by the declared
pregnant woman and by the embryo/fetus(15).
Due to privacy provisions noted in the following section, if an
adjustment of working conditions is necessary, the Radiation
Safety Office will consult with the declared pregnant woman;
discuss with her any adjustment of working conditions that may
be required; and obtain her written authorization prior to
discussing such adjustments with her supervisor or Responsible
Investigator.
The employment status of the declared pregnant woman is
explicitly protected. The Rules of the City of New York, Article
175(16) states that: "No licensee, registrant, or
contractor or subcontractor of a licensee or registrant shall
discharge or in any manner discriminate against any worker
because of the exercise by such worker on behalf of such worker
or others of any option afforded by this Code." A notice of
alleged violation of this or any other requirement of RCNY
Article 175 may be filed in writing with the City of New York,
Department of Health, Bureau of Radiological Health which is
empowered to inspect the licensee and levy penalties if a
violation is determined to exist.
4. Records, informing workers of exposure
received during gestation, reports
A) Records
Declarations and records required under this policy should be
protected from public disclosure because of their personal
privacy nature. These records are protected by New York State
and Federal privacy statutes(17). The Declaration of
Pregnancy Form, including the estimated date of conception will
be maintained in a separate file from the dose records of the
declared pregnant woman and the embryo/fetus(18). The
Declaration of Pregnancy Form will be over-stamped or bear the
prominent heading, "CONFIDENTIAL." Such records shall be
retained until the City of New York, Bureau of Radiological
Health authorizes disposition(19).
B) Informing workers of exposure received
during gestation
The Radiation Safety Office shall advise each worker annually of
the worker’s exposure to radiation(20) and shall
furnish a report of the worker’s (or former worker’s) exposure
to sources of radiation at their request(21). If the
Radiation Safety Office is required to report to the City of New
York, Bureau of Radiological Health any exposure of an
individual to radiation or radioactive material, the Radiation
Safety Office shall also notify the individual at a time not
later than the transmittal to the Bureau of Radiological Health(22).
Notification or report to a worker shall be in writing, shall
include appropriate identification of the licensed institution,
Columbia University Medical Center, the name and social security
number of the individual worker, their exposure information and
shall contain the statement, "This report is furnished to you
under the provisions of Para.175.04 of the New York City Health
Code. You should preserve this report for further reference(23)."
C) Reports
The Radiation Safety Office shall submit a written report to the
City of New York Bureau of Radiological Health within thirty
days after learning that the 5 mSv (0.5 rem) dose limit for an
embryo/fetus of a declared pregnant woman has been exceeded(24).
The report shall describe the extent of exposure of the
embryo/fetus and the declared pregnant woman to radiation and
radioactive materials and include as appropriate; estimates of
each individual’s dose, the levels of radiation and
concentrations of radioactive materials involved; the cause of
the elevated exposures, dose rates and concentrations; and
corrective steps taken or planned to ensure against a recurrence(25)
This report shall be prepared so that identifiers such as name,
social security number and date of birth are stated in a
separate and detachable portion of the report in order to
conform to privacy laws(26).
ALARA review(27) of the declared pregnant woman’s
Personnel Radiation Dosimetry Report will be performed on a
monthly basis to avoid a monthly exposure of more than 0.5 mSv
(0.05 rem). Records will be kept in the form specified above.
The declared pregnant woman will be notified in writing if her
monthly radiation dose exceeds the 0.05 rem ALARA level and an
appropriate ALARA investigation will be performed. The CUMC
Joint Radiation Safety Committee will receive ALARA reports for
declared pregnant women with identifiers such as name, social
security number and date of birth in a separate and detachable
portion of the report.
5. Provision of further information
Any individual or group having questions related to the
radiation protection of the embryo/fetus is strongly encouraged
to contact the Radiation Safety Office, telephone number (212)
305-0303, at the location cited above. The Radiation Safety
Office will provide appropriate and confidential education and
counseling.
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