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No. 447 複数の医療機関に勤務する場合の放射線管理

複数の医療機関に勤務する場合の放射線管理はどうすればよいですか?

記事作成日:2022/12/19 最終更新日: 2023/12/19

雇用主側での連携も求められています。

IAEA

GSR part3

Records of occupational exposure

3.105. Records of occupational exposure shall include:
(c) When a worker is or has been exposed while in the employ of more than
one employer, information on the dates of employment with each employer
and on the doses, exposures and intakes in each such employment;

GSG-7

Scope of the radiation protection programme

3.60. The radiation protection programme should document the following, with an appropriate level of detail:
(a) The assignment of responsibilities for protection and safety for workers to different management levels, including corresponding organizational arrangements and, if applicable (e.g. in the case of itinerant workers), the allocation of the respective responsibilities between employers and the registrant or licensee;

3.149. Particular attention should be paid to contractors, including subcontractors and itinerant workers. Employers should cooperate to ensure that contractors, including subcontractors and itinerant workers, are provided with the necessary information and with appropriate training (see paras 6.73–6.76).

ITINERANT WORKERS

6.21. For the purposes of this Safety Guide, itinerant workers are occupationally exposed persons who work in supervised areas or controlled areas at various locations and who are not employees of the management of the facility where they are working [44]. Itinerant workers can be self-employed or can be employed by a contractor (or similar legal entity) that provides services at the facilities of other employers. (Such a facility may or may not be a registrant or licensee or be otherwise under regulatory control.)
6.22. The management of a facility and the contractor are both employers. The management of a facility has primary control of the facility, while the contractor provides services under contract. The employees of a contractor, when working in supervised areas or controlled areas at a facility that is not managed by, or under the primary control of, the contractor, will fall within the definition of itinerant workers. In more complex situations, a contractor might itself contract work to a subcontractor, whereupon the employees of both contractor and subcontractor could be itinerant workers. When the contractor is a self-employed person, that person is regarded as being, and as having the duties of, both an employer and a worker.

SSG-46

Persons who work in more than one place

3.123. Some individuals might work in more than one radiology facility. The facilities may be quite separate entities in terms of ownership and management, or they may have common ownership but separate management, or they may even have common ownership and management but be physically quite separate. Regardless of the ownership and management structure, the occupational radiation protection requirements for the particular radiology facility apply when the person is working in that facility. As described in para. 3.106, a dosimeter issued for individual monitoring should be worn only in the facility for which it is issued, as this facilitates the effective optimization of protection and safety in that facility. This approach is logistically more easily implemented, since each physical site has its own dosimeters, and so there is no need to transport dosimeters between facilities, with the risk of losing or forgetting them. In cases where the facilities are under common ownership, it may be seen as an unnecessary financial burden to provide more than one set of dosimeters for staff that work in more than one of its facilities. However, the radiation protection advantages of having the dosimeter results linked to a person’s work in only one radiology facility remain (see also para. 3.125).
3.124. There is, however, an important additional consideration, namely the need to ensure compliance with the occupational dose limits. Any person who works in more than one radiology facility should notify the licensee for each of those facilities. Each licensee, through its RPO, should establish formal contact with the licensees of the other radiology facilities and their RPOs, so that each facility has an arrangement to ensure that a personal dosimeter is available and that there is an ongoing record of the occupational doses for that person in all the facilities where he or she works.
3.125. Some individuals, such as consultant medical physicists or service engineers, might perform work in many radiology facilities and, in addition, in other medical radiation facilities. They can be employed by a company or be self-employed, providing contracted services to the radiology facility and the other facilities. In such cases, it is simpler for the company or the self-employed person to provide the dosimeters for individual monitoring. Therefore, in these cases, a worker uses the same dosimeter for work performed in all radiology facilities (and other medical radiation facilities) in the monitoring period.

ORPASでの指摘例

S8: Suggestion: Lanka Hospitals should consider providing arrangements for the protection and safety of itinerant workers.

国内法令

業務受託業者の義務

なお、エックス線装置等の保守点検業務を業者に委託している場合、保守点検を実施する者の当該業務による職業被ばくの管理は病院等の管理者ではなく労働安全衛生法(昭和47年法律第57号)に基づく業務受託業者の義務であることから、放射線診療従事者等とはみなさないものであること。

海外

インド

Radiation workers employed in multiple centres:

If professionals/ workers are working inmultiple radiation facilities (part time employees/ consultants etc.), the Licencee of each facilityhas to separately provide TLD to such workers, to be used while working at his/her premises.

カナダ

Alberta Occupational Health and Safety (OHS)

• if an employer has more than one facility, each facilitymust register, use and monitor its own dosimeter badges• staff cannot use the personal dosimeter(s) for multiple facilities

実態調査

Frye S, Reynolds AM, Botkin C, Muzaffar R, Osman MM. Monitoring Individual Occupational Radiation Exposure at Multiple Institutions. J Nucl Med Technol. 2021 Nov 8:jnmt.120.243154. doi: 10.2967/jnmt.120.243154. Epub ahead of print. PMID: 34750239.