If you have a radiation license at your facility, but the only isotopes in use are low energy emitters that are not detectable by dosimeters, be sure to document why a dosimetry program is not in place.
Dosimeters, which are used to monitor radiation workers exposure to radioactive materials, are required when adults are likely to receive a dose in excess of 10% of annual occupational exposure limits. If the only isotopes in use are not detectable by dosimeters, it is a good idea to place a note to file in the central safety files to document that a dosimetry program will be put in to place if work with higher energy emitters begins.
Documentation is a large part of any EHS program, and notes to file are an excellent way to document elements of your EHS program. As discussions are held and decisions are made, be sure to make your note to file while the information is fresh in your mind and before you forget. While establishing your radiation program documentation, be sure to include a note to file regarding dosimeters as necessary.