Washington State University
SAFETY POLICIES AND PROCEDURES MANUAL

RADIATION SAFETY
9.50
Revised 3-02
Radiation Safety Office
335-8916

Prenatal Radiation Exposure

PDF link

SUPERVISOR'S RESPONSIBILITY

Immediate supervisors are responsible for ensuring that any woman who works with ionizing radiation reads "Possible Health Risks to Children of Women Who Are Exposed to Radiation During Pregnancy" below.

Women employees must sign the Prenatal Radiation Exposure Statement form after reading "Possible Health Risks to Children of Women Who Are Exposed to Radiation During Pregnancy."

Print the Prenatal Radiation Exposure Statement form on page 9.50.16.

Return the original signed form to the Radiation Safety Office. Retain a copy for departmental files.

See the PDF master form:
9.50-16: Prenatal Radiation Exposure Statement
Print or complete onscreen and print as needed




POSSIBLE HEALTH RISKS TO CHILDREN OF WOMEN
WHO ARE EXPOSED TO RADIATION DURING PREGNANCY*

* Adopted from Nuclear Regulatory Commission Guide 8.13, revised June 1999.
(See reprint of NRC Guide 8.13 below.)

Some recent studies have shown that the risk of leukemia and other cancer-type diseases in children increases if the mother is exposed to a significant amount of radiation during pregnancy. According to a report by the National Academy of Sciences, the incidence of leukemia among children from birth to 10 years of age in the United States could rise from 3.7 cases in 10,000 children to 5.6 cases in 10,000 children if the children were exposed to 1 rem of radiation before birth (a "rem" is a measure of radiation). The Academy has also estimated that an equal number of other types of cancerous diseases could result from this level of radiation. Although other scientific studies have shown a much smaller effect from radiation, the Washington State University Radiation Safety Committee wants women in radiation work to be aware of any possible risk so that they can take steps they think appropriate to protect their offspring.

As an employee of Washington State University involved in radiation work, you may be exposed to more radiation than the general public. However, the state of Washington has established a basic exposure limit for all occupationally exposed adults of 1.25 rems per calendar quarter, or 5 rems per year. No clinical evidence of harm would be expected in an adult working within these levels for a lifetime. Because the risks of undesirable effects may be greater for young people, individuals under 18 years of age are permitted to be exposed to only 10 percent of the adult occupational limits. (This lower limit is also applied to members of the general public.)

The scientific organization called the National Council on Radiation Protection and Measurements (NCRP) has recommended that because unborn babies may be more sensitive to radiation than adults, their radiation dose as a result of occupational exposure of the mother should not exceed 0.5 rem. Other scientific groups, including the International Commission on Radiation Protection, have also stressed the need to keep radiation doses to unborn children as low as is reasonably achievable.

All state of Washington radioactive material licensees are now required to inform all individuals who work in a restricted area of the health protection problems associated with radiation exposure (WAC 246-222-030). This instruction would, in many cases, include information on the possible risks to unborn babies.

The regulations also state that licensees should keep radiation exposures as low as is reasonably achievable (WAC 246-220-007). According to the National Council on Radiation Protection and Measurements, vigorous efforts should be made to keep the radiation exposure of an embryo or fetus at the very lowest practicable level during the entire period of pregnancy.

Thus, it is the responsibility of the University to take all practicable steps to reduce your radiation exposure. Then it is your responsibility to decide whether the exposure you are receiving is sufficiently low to protect your unborn child. The advice of the Radiation Safety Officer at the Nuclear Radiation Center should be obtained to determine whether radiation levels in your working areas are high enough that a baby could receive 0.5 rem or more before birth. If so, the alternatives that you might want to consider are:

a) If you are now pregnant or expect to be soon, you could decide not to accept or continue assignments in these areas.

b) You could reduce your exposure, where possible, by decreasing the amount of time you spend in the radiation area, increasing your distance from the radiation source, and using shielding.

c) If you do become pregnant, you could ask your employer to reassign you to areas involving less exposure to radiation. If this is not possible, you might consider leaving your job. If you decide to take such steps, do so without delay. The unborn child is most sensitive to radiation during the first three months of pregnancy.

d) You could delay having children until you are no longer working in an area where the radiation dose to your unborn child could exceed 0.5 rem.


You may also, of course, choose to:

e) Continue working in the higher radiation areas, but with full awareness that you are doing so at some small increased risk for your unborn child.


The following facts should be noted to help you make a decision:

1. The first three months of pregnancy are the most important, so you should make your decision quickly.

2. In most cases of occupational exposure, the actual dose received by the unborn baby is less than the dose received by the mother because some of the dose is absorbed by the mother's body.

3. At the present occupational exposure limit, the actual risk to the unborn baby is small, but experts disagree on the exact amount of risk.

4. There is no need to be concerned about sterility or loss of your ability to bear children. The radiation dose required to produce such effects is more than 100 times larger than state of Washington dose limits for adults.

5. Even if you work in an area where you receive only 0.5 rem per three-month period, in nine months you could receive 1.5 rems, and the unborn baby could receive more than 0.5 rem, the full-term limit suggested by the NCRP. Therefore, if you decide to restrict your unborn baby's exposure as recommended by the NCRP, be aware that the 0.5 rem limit to the unborn baby applies to the full nine-month pregnancy.


The remainder of this document contains a brief explanation of radiation and its effects on humans. As you will see, some radiation is present everywhere and the levels of radiation most radiation workers receive are not much larger than these natural levels. Because the radiation levels in the facility where you will be working are required by law to be kept quite low, there is not considered to be a significant health risk to individual adult employees.

Discussion of Radiation

The amount of radiation an individual receives is called the "dose" and is measured in "rems." The average individual in the United States accumulates a dose of one rem from natural sources every 12 years. The dose from natural radiation is higher in some states, such as Colorado, Wyoming, and South Dakota, primarily because of cosmic radiation. There, the average individual gets one rem every 8 years.

Natural background radiation levels are also much higher in certain local areas. A dose of one rem may be received in some areas on the beach at Guarapari, Brazil in only about 9 days, and some people in Kerala, India get a dose of one rem every 5 months.

Many people receive additional radiation for medical reasons. In 1970, an estimated 212 million X-ray examinations were performed in the United States. The estimated average surface skin dose from one radiographic chest X-ray is 0.027 rem. The estimated average surface skin dose per abdominal X-ray is 0.62 rem.*

Radiation, like many things, can be harmful. A large dose to the whole body (such as 600 rems in one day) would probably cause death in about 30 days, but such large doses result only from rare accidents. Control of exposure to radiation is based on the assumption that any exposure, no matter how small, involves some risk. The occupational exposure limits are set so low, however, that medical evidence gathered over the past 50 years indicates no clinically observable injuries to individuals due to radiation exposures when the established radiation limits are not exceeded. This was true even for exposures received under the early occupational exposure limits, which were many times higher than the present limits. Thus the risk to individuals at the occupational exposure levels is considered to be very low. However, it is impossible to say that the risk is zero. To decrease the risk still further, employees are expected to keep actual exposures as far below the limits as is reasonably achievable.

The current exposure limits for people working with radiation have been developed and carefully reviewed by nationally and internationally recognized groups of scientists. It must be remembered, however, that these limits are for adults. Special consideration is appropriate when the individual being exposed is, or may be, an expectant mother, because the exposure of an unborn child may also be involved.

Prenatal Irradiation

The prediction that an unborn child would be more sensitive to radiation than an adult is supported by observations for relatively large doses. Large doses delivered before birth alter both physical development and behavior in experimentally exposed animals. A report of the National Academy of Sciences states that short-term doses in the range of 10 to 20 rems cause subtle changes in the nerve cells of unborn and infant rats. The report also states, however, that no radiation induced changes in development have been demonstrated to result in experimental animals from doses up to about 1 rem per day extended over a large part of the period before birth.

The National Academy of Sciences also noted that doses of 25 to 50 rems to a pregnant human may cause growth disturbances in her offspring. Such doses substantially exceed, of course, the maximum permissible occupational exposure limits.

Concern about prenatal exposure (i.e., exposure of a child while in the mother's uterus) at the permissible occupational limits is primarily based on the possibility that cancer-type illnesses (especially leukemia) may develop during the first 10 years of the child's life. Several studies have been performed to evaluate this risk. One study involved the follow-up of 77,000 children exposed to radiation before birth (because of diagnostic abdominal X-rays made for medical purposes during their mother's pregnancy). Another study involved the follow-up of 20,000 such children. In addition, 1292 children who received prenatal exposure during the bombing of Hiroshima and Nagasaki were studied. Although contradictory results have been obtained, most of the evidence suggests a relationship between prenatal exposure and an increased risk of childhood cancer.

Summary

Occupational exposures to radiation are being kept low. However, qualified scientists have recommended that the radiation dose to an embryo or fetus as a result of occupational exposure of the expectant mother should not exceed 0.5 rem because of possible increased risk of childhood leukemia and cancer. Since this 0.5 rem is lower than the dose generally permitted to adult workers, women may want to take special actions to avoid receiving higher exposures, just as they might stop smoking during pregnancy or might climb stairs more carefully to reduce possible risks to their unborn children.

* "Pre-Release Report: X-Ray Exposure Study (XES) Revised Estimates of 1964 and 1970 Genetically Significant Dose," February 4, 1975, U.S. Department of Health, Education, and Welfare, Public Health Service, Federal Drug Administration, Bureau of Radiological Health.


 NUCLEAR REGULATORY COMMISSION

REGULATORY GUIDE
OFFICE OF NUCLEAR REGULATORY RESEARCH

REGULATORY GUIDE 8.13
(Draft was issued as DG-8014)

INSTRUCTION CONCERNING PRENATAL RADIATION EXPOSURE


A. INTRODUCTION

The Code of Federal Regulations in 10 CFR Part 19, "Notices, Instructions and Reports to Workers: Inspection and Investigations," in Section 19.12, "Instructions to Workers," requires instruction in "the health protection problems associated with exposure to radiation and/or radioactive material, in precautions or procedures to minimize exposure, and in the purposes and functions of protective devices employed." The instructions must be "commensurate with potential radiological health protection problems present in the work place."

The Nuclear Regulatory Commission's (NRC's) regulations on radiation protection are specified in 10 CFR Part 20, "Standards for Protection Against Radiation;" and 10 CFR 20.1208, "Dose to an Embryo/Fetus," requires licensees to "ensure that the dose to an embryo/fetus during the entire pregnancy, due to occupational exposure of a declared pregnant woman, does not exceed 0.5 rem (5 mSv)." Section 20.1208 also requires licensees to "make efforts to avoid substantial variation above a uniform monthly exposure rate to a declared pregnant woman." A declared pregnant woman is defined in 10 CFR 20.1003 as a woman who has voluntarily informed her employer, in writing, of her pregnancy and the estimated date of conception.

This regulatory guide is intended to provide information to pregnant women, and other personnel, to help them make decisions regarding radiation exposure during pregnancy. This Regulatory Guide 8.13 supplements Regulatory Guide 8.29, "Instruction Concerning Risks from Occupational Radiation Exposure" (Ref. 1), which contains a broad discussion of the risks from exposure to ionizing radiation.

Other sections of the NRC's regulations also specify requirements for monitoring external and internal occupational dose to a declared pregnant woman. In 10 CFR 20.1502, "Conditions Requiring Individual Monitoring of External and Internal Occupational Dose," licensees are required to monitor the occupational dose to a declared pregnant woman, using an individual monitoring device, if it is likely that the declared pregnant woman will receive, from external sources, a deep dose equivalent in excess of 0.1 rem (1 mSv). According to Paragraph (e) of 10 CFR 20.2106, "Records of Individual Monitoring Results," the licensee must maintain records of dose to an embryo/fetus if monitoring was required, and the records of dose to the embryo/fetus must be kept with the records of dose to the declared pregnant woman. The declaration of pregnancy must be kept on file, but may be maintained separately from the dose records. The licensee must retain the required form or record until the Commission terminates each pertinent license requiring the record.

The information collections in this regulatory guide are covered by the requirements of 10 CFR Parts 19 or 20, which were approved by the Office of Management and Budget, approval numbers 3150-0044 and 3150-0014, respectively. The NRC may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.


B. DISCUSSION

As discussed in Regulatory Guide 8.29 (Ref. 1), exposure to any level of radiation is assumed to carry with it a certain amount of risk. In the absence of scientific certainty regarding the relationship between low dose exposure and health effects, and as a conservative assumption for radiation protection purposes, the scientific community generally assumes that any exposure to ionizing radiation may cause undesirable biological effects and that the likelihood of these effects increases as the dose increases. At the occupational dose limit for the whole body of 5 rem (50 mSv) per year, the risk is believed to be very low.

The magnitude of risk of childhood cancer following in utero exposure is unce"tain in that both negative and positive studies have been reported. The data from these studies "are consistent with a lifetime cancer risk resulting from exposure during gestation which is two to three times that for the adult." (NCRP Report No. 116, Ref. 2) The NRC has reviewed the available scientific literature and has concluded that the 0.5 rem (5 mSv) limit specified in 10 CFR 20.1208 provides an adequate margin of protection for the embryo/fetus. This dose limit reflects the desire to limit the total lifetime risk of leukemia and other cancers associated with radiation exposure during pregnancy.

In order for a pregnant worker to take advantage of the lower exposure limit and dose monitoring provisions specified in 10 CFR Part 20, the woman must declare her pregnancy in writing to the licensee. A form letter for declaring pregnancy is provided in this guide or the licensee may use its own form letter for declaring pregnancy. A separate written declaration should be submitted for each pregnancy.


C. REGULATORY POSITION

1. Who Should Receive Instruction

Female workers who require training under 10 CFR 19.12 should be provided with the information contained in this guide. In addition to the information contained in Regulatory Guide 8.29 (Ref. 1), this information may be included as part of the training required under 10 CFR 19.12.

2. Providing Instruction

The occupational worker may be given a copy of this guide with its Appendix, an explanation of the contents of the guide, and an opportunity to ask questions and request additional information. The information in this guide and Appendix should also be provided to any worker or supervisor who may be affected by a declaration of pregnancy or who may have to take some action in response to such a declaration.

Classroom instruction may supplement the written information. If the licensee provides classroom instruction, the instructor should have some knowledge of the biological effects of radiation to be able to answer questions that may go beyond the information provided in this guide. Videotaped presentations may be used for classroom instruction. Regardless of whether the licensee provides classroom training, the licensee should give workers the opportunity to ask questions about information contained in this Regulatory Guide 8.13. The licensee may take credit for instruction that the worker has received within the past year at other licensed facilities or in other courses or training.

3. Licensee's Policy on Declared Pregnant Women

The instruction provided should describe the licensee's specific policy on declared pregnant women, including how those policies may affect a woman's work situation. In particular, the instruction should include a description of the licensee's policies, if any, that may affect the declared pregnant woman's work situation after she has filed a written declaration of pregnancy consistent with 10 CFR 20.1208.

The instruction should also identify who to contact for additional information as well as identify who should receive the written declaration of pregnancy. The recipient of the woman's declaration may be identified by name (e.g., John Smith), position (e.g., immediate supervisor, the radiation safety officer), or department (e.g., the personnel department).

4. Duration of Lower Dose Limits for the Embryo/Fetus

The lower dose limit for the embryo/fetus should remain in effect until the woman withdraws the declaration in writing or the woman is no longer pregnant. If a declaration of pregnancy is withdrawn, the dose limit for the embryo/fetus would apply only to the time from the estimated date of conception until the time the declaration is withdrawn. If the declaration is not withdrawn, the written declaration may be considered expired one year after submission.

5. Substantial Variations Above a Uniform Monthly Dose Rate

According to 10 CFR 20.1208(b), "The licensee shall make efforts to avoid substantial variation above a uniform monthly exposure rate to a declared pregnant woman so as to satisfy the limit in paragraph (a) of this section," that is, 0.5 rem (5 mSv) to the embryo/fetus. The National Council on Radiation Protection and Measurements (NCRP) recommends a monthly equivalent dose limit of 0.05 rem (0.5 mSv) to the embryo/fetus once the pregnancy is known (Ref. 2). In view of the NCRP recommendation, any monthly dose of less than 0.1 rem (1 mSv) may be considered as not a substantial variation above a uniform monthly dose rate and as such will not require licensee justification. However, a monthly dose greater than 0.1 rem (1 mSv) should be justified by the licensee.


D. IMPLEMENTATION

The purpose of this section is to provide information to licensees and applicants regarding the NRC staff's plans for using this regulatory guide.

Unless a licensee or an applicant proposes an acceptable alternative method for complying with the specified portions of the NRC's regulations, the methods described in this guide will be used by the NRC staff in the evaluation of instructions to workers on the radiation exposure of pregnant women.


REFERENCES

1. USNRC, "Instruction Concerning Risks from Occupational Radiation Exposure," Regulatory Guide 8.29, Revision 1, February 1996.

2. National Council on Radiation Protection and Measurements, Limitation of Exposure to Ionizing Radiation, NCRP Report No. 116, Bethesda, MD, 1993.


REGULATORY ANALYSIS

A separate regulatory analysis was not prepared for this regulatory guide. A regulatory analysis prepared for 10 CFR Part 20, "Standards for Protection Against Radiation" (56 FR 23360), provides the regulatory basis for this guide and examines the costs and benefits of the rule as implemented by the guide. A copy of the "Regulatory Analysis for the Revision of 10 CFR Part 20" (PNL-6712, November 1988) is available for inspection and copying for a fee at the NRC Public Document Room, 2120 L Street NW, Washington, DC, as an enclosure to Part 20 (56 FR 23360).


APPENDIX

QUESTIONS AND ANSWERS CONCERNING PRENATAL RADIATION EXPOSURE

1. Why am I receiving this information?

The NRC's regulations (in 10 CFR 19.12, "Instructions to Workers") require that licensees instruct individuals working with licensed radioactive materials in radiation protection as appropriate for the situation. The instruction below describes information that occupational workers and their supervisors should know about the radiation exposure of the embryo/fetus of pregnant women.

The regulations allow a pregnant woman to decide whether she wants to formally declare her pregnancy to take advantage of lower dose limits for the embryo/fetus. This instruction provides information to\ help women make an informed decision whether to declare a pregnancy.

2. If I become pregnant, am I required to declare my pregnancy?

No. The choice whether to declare your pregnancy is completely voluntary. If you choose to declare your pregnancy, you must do so in writing and a lower radiation dose limit will apply to your embryo/fetus. If you choose not to declare your pregnancy, you and your embryo/fetus will continue to be subject to the same radiation dose limits that apply to other occupational workers.

3. If I declare my pregnancy in writing, what happens?

If you choose to declare your pregnancy in writing, the licensee must take measures to limit the dose to your embryo/fetus to 0.5 rem (5 millisievert) during the entire pregnancy. This is one-tenth of the dose that an occupational worker may receive in a year. If you have already received a dose exceeding 0.5 rem (5 mSv) in the period between conception and the declaration of your pregnancy, an additional dose of 0.05 rem (0.5 mSv) is allowed during the remainder of the pregnancy. In addition, 10 CFR 20.1208, "Dose to an Embryo/Fetus," requires licensees to make efforts to avoid substantial variation above a uniform monthly dose rate so that all the 0.5 rem (5 mSv) allowed dose does not occur in a short period during the pregnancy.

This may mean that, if you declare your pregnancy, the licensee may not permit you to do some of your normal job functions if those functions would have allowed you to receive more than 0.5 rem, and you may not be able to have some emergency response responsibilities.

4. Why do the regulations have a lower dose limit for the embryo/fetus of a declared pregnant woman than for a pregnant worker who has not declared?

A lower dose limit for the embryo/fetus of a declared pregnant woman is based on a consideration of greater sensitivity to radiation of the embryo/fetus and the involuntary nature of the exposure. Several scientific advisory groups have recommended (References 1 and 2) that the dose to the embryo/fetus be limited to a fraction of the occupational dose limit.

5. What are the potentially harmful effects of radiation exposure to my embryo/fetus?

The occurrence and severity of health effects caused by ionizing radiation are dependent upon the type and total dose of radiation received, as well as the time period over which the exposure was received. See Regulatory Guide 8.29, "Instruction Concerning Risks from Occupational Exposure" (Ref. 3), for more information. The main concern is embryo/fetal susceptibility to the harmful effects of radiation such as cancer.

6. Are there any risks of genetic defects?

Although radiation injury has been induced experimentally in rodents and insects, and in the experiments was transmitted and became manifest as hereditary disorders in their offspring, radiation has not been identified as a cause of such effect in humans. Therefore, the risk of genetic effects attributable to radiation exposure is speculative. For example, no genetic effects have been documented in any of the Japanese atomic bomb survivors, their children, or their grandchildren.

7. What if I decide that I do not want any radiation exposure at all during my pregnancy?

You may ask your employer for a job that does not involve any exposure at all to occupational radiation dose, but your employer is not obligated to provide you with a job involving no radiation exposure. Even if you receive no occupational exposure at all, your embryo/fetus will receive some radiation dose (on average 75 mrem (0.75 mSv)) during your pregnancy from natural background radiation.

The NRC has reviewed the available scientific literature and concluded that the 0.5 rem (5 mSv) limit provides an adequate margin of protection for the embryo/fetus. This dose limit reflects the desire to limit the total lifetime risk of leukemia and other cancers. If this dose limit is exceeded, the total lifetime risk of cancer to the embryo/fetus may increase incrementally. However, the decision on what level of risk to accept is yours. More detailed information on potential risk to the embryo/fetus from radiation exposure can be found in References 2-10.

8. What effect will formally declaring my pregnancy have on my job status?

Only the licensee can tell you what effect a written declaration of pregnancy will have on your job status. As part of your radiation safety training, the licensee should tell you the company's policies with respect to the job status of declared pregnant women. In addition, before you declare your pregnancy, you may want to talk to your supervisor or your radiation safety officer and ask what a declaration of pregnancy would mean specifically for you and your job status.

In many cases you can continue in your present job with no change and still meet the dose limit for the embryo/fetus. For example, most commercial power reactor workers (approximately 93 percent) receive, in 12 months, occupational radiation doses that are less than 0.5 rem (5 mSv) (Ref. 11). The licensee may also consider the likelihood of increased radiation exposures from accidents and abnormal events before making a decision to allow you to continue in your present job.

If your current work might cause the dose to your embryo/fetus to exceed 0.5 rem (5 mSv), the licensee has various options. It is possible that the licensee can and will make a reasonable accommodation that will allow you to continue performing your current job, for example, by having another qualified employee do a small part of the job that accounts for some of your radiation exposure.

9. What information must I provide in my written declaration of pregnancy?

You should provide, in writing, your name, a declaration that you are pregnant, the estimated date of conception (only the month and year need be given), and the date that you give the letter to the licensee. You may follow the form letter example in the PDF version of 9.50.12 or write your own letter.

10. To declare my pregnancy, do I have to have documented medical proof that I am pregnant?

NRC regulations do not require that you provide medical proof of your pregnancy. However, NRC regulations do not preclude the licensee from requesting medical documentation of your pregnancy, especially if a change in your duties is necessary in order to comply with the 0.5 rem (5 mSv) dose limit.

11. Can I tell the licensee orally rather than in writing that I am pregnant?

No. The regulations require that the declaration must be in writing.

12. If I have not declared my pregnancy in writing, but the licensee suspects that I am pregnant, do the lower dose limits apply?

No. The lower dose limits for pregnant women apply only if you have declared your pregnancy in writing. The United States Supreme Court has ruled (in United Automobile Workers International Union v. Johnson Controls, Inc., 1991) that "Decisions about the welfare of future children must be left to the parents who conceive, bear, support, and raise them rather than to the employers who hire those parents." (Reference 7) The Supreme Court also ruled that your employer may not restrict you from a specific job "because of concerns about the next generation." Thus, the lower limits apply only if you choose to declare your pregnancy in writing.

13. If I am planning to become pregnant but am not yet pregnant and I inform the licensee of that in writing, do the lower dose limits apply?

No. The requirement for lower limits applies only if you declare in writing that you are already pregnant.

14. What if I have a miscarriage or find out that I am not pregnant?

If you have declared your pregnancy in writing, you should promptly inform the licensee in writing that you are no longer pregnant. However, if you have not formally declared your pregnancy in writing, you need not inform the licensee of your nonpregnant status.

15. How long is the lower dose limit in effect?

The dose to the embryo/fetus must be limited until you withdraw your declaration in writing or you inform the licensee in writing that you are no longer pregnant. If the declaration is not withdrawn, the written declaration may be considered expired one year after submission.

16. If I have declared my pregnancy in writing, can I revoke my declaration of pregnancy even if I am still pregnant?

Yes, you may. The choice is entirely yours. If you revoke your declaration of pregnancy, the lower dose limit for the embryo/fetus no longer applies.

17. What if I work under contract at a licensed facility?

The regulations state that you should formally declare your pregnancy to the licensee in writing. The licensee has the responsibility to limit the dose to the embryo/fetus.

18. Where can I get additional information?

The references to this Appendix contain helpful information, especially Reference 3, NRC's Regulatory Guide 8.29, "Instruction Concerning Risks from Occupational Radiation Exposure," for general information on radiation risks. The licensee should be able to give this document to you.

For information on legal aspects, see Reference 7, "The Rock and the Hard Place: Employer Liability to Fertile or Pregnant Employees and Their Unborn Children-What Can the Employer Do?" which is an article in the journal Radiation Protection Management.

You may telephone the NRC Headquarters at 301-415-7000. Legal questions should be directed to the Office of the General Counsel, and technical questions should be directed to the Division of Industrial and Medical Nuclear Safety.

You may also telephone the NRC Regional Offices at the following numbers: Region I, 610-337-5000; Region II, 404-562-4400; Region III, 630-829-9500; and Region IV, 817-860-8100. Legal questions should be directed to the Regional Counsel, and technical questions should be directed to the Division of Nuclear Materials Safety.


BIBLIOGRAPHY

1. National Council on Radiation Protection and Measurements, Limitation of Exposure to Ionizing Radiation, NCRP Report No. 116, Bethesda, MD, 1993.

2. International Commission on Radiological Protection, 1990 Recommendations of the International Commission on Radiological Protection, ICRP Publication 60, Ann. ICRP 21: No. 1-3, Pergamon Press, Oxford, UK, 1991.

3. USNRC, "Instruction Concerning Risks from Occupational Radiation Exposure," Regulatory Guide 8.29, Revision 1, February 1996.(1)

4. Committee on the Biological Effects of Ionizing Radiations, National Research Council, Health Effects of Exposure to Low Levels of Ionizing Radiation (BEIR V), National Academy Press, Washington, DC, 1990.

5. United Nations Scientific Committee on the Effects of Atomic Radiation, Sources and Effects of Ionizing Radiation, United Nations, New York, 1993.

6. R. Doll and R. Wakeford, "Risk of Childhood Cancer from Fetal Irradiation," The British Journal of Radiology, 70, 130-139, 1997.

7. David Wiedis, Donald E. Jose, and Timm O. Phoebe, "The Rock and the Hard Place: Employer Liability to Fertile or Pregnant Employees and Their Unborn Children-What Can the Employer Do?" Radiation Protection Management, 11, 41-49, January/February 1994.

8. National Council on Radiation Protection and Measurements, Considerations Regarding the Unintended Radiation Exposure of the Embryo, Fetus, or Nursing Child, NCRP Commentary No. 9, Bethesda,MD, 1994.

9. National Council on Radiation Protection and Measurements, Risk Estimates for Radiation Protection, NCRP Report No. 115, Bethesda, MD, 1993.

10. National Radiological Protection Board, Advice on Exposure to Ionising Radiation During Pregnancy, National Radiological Protection Board, Chilton, Didcot, UK, 1998.

11. M.L. Thomas and D. Hagemeyer, "Occupational Radiation Exposure at Commercial Nuclear Power Reactors and Other Facilities, 1996," Twenty-Ninth Annual Report, NUREG-0713, Vol. 18, USNRC, 1998.(2)
____________________________

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USNRC REGULATORY GUIDES

Regulatory guides are issued to describe and make available to the public such information as methods acceptable to the NRC staff implementing specific parts of the Commission's regulations, techniques used by the staff in evaluating specific problems or postulated accidents, and data needed by the NRC staff in its review of applications for permits and licenses. Regulatory guides are not substitutes for regulations, and compliance with them is not required. Methods and solutions different from those set out in the guides will be acceptable if they provide a basis for the findings requisite to the issuance or continuance of a permit or license by the Commission.

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