SEC-010: Radiation Protection during Pregnancy

Date: 08/01/2005 Status: Final
Last Revised: 09/27/2011
Policy Type: University
Oversight Executive: Vice President for Research
Applies To: Academic Division and the Medical Center.
Reason for Policy:

State and Federal regulations and the University of Virginia's license to use radioactive material require that radiation workers receive 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. They also require 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).”

Definition of Terms in Statement:
  • Declared Pregnant Woman:

    A woman who has voluntarily informed the licensee, in writing, of her pregnancy and the estimated date of conception. The declaration remains in effect until the declared pregnant woman withdraws the declaration in writing or is no longer pregnant.

  • Radiation Worker:

    An individual engaged in activities licensed by the Nuclear Regulatory Commission or the State of Virginia and controlled by a licensee. The individual’s assigned duties involve exposure to radiation or to radioactive material from licensed and unlicensed sources of radiation.

  • rem (Sv):

    Units used to quantify radiation dose.

Policy Statement:

As part of the University’s policy for Utilization of Radioactive Materials, only appropriately trained personnel will handle and use licensed material without undue hazard to themselves, other workers or members of the public. Female workers who require radiation protection training should be provided with information concerning Prenatal Radiation Exposure.

  1. Regulatory Position:
    The Commonwealth of Virginia and Nuclear Regulatory Commission (NRC) regulations on radiation protection are specified in 12 Virginia Administrative Code (VAC) 5-481 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).” This section 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 the regulations as a woman who has voluntarily informed her employer, in writing, of her pregnancy and the estimated date of conception.

  2. Background:
    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 uncertain 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.

    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 in NRC Reg. Guide 8.13). 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.

    The NRC has published a Regulatory Guide; Regulatory Guide 8.13 - Instruction Concerning Prenatal Radiation Exposure. This guide is available through Environmental Health & Safety (EHS) 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. You may visit the EHS website or call 2-4911 to obtain this information.

  3. Instruction for Declaration of Pregnancy:
    If you plan to become pregnant or are pregnant, you have several choices regarding declaration of pregnancy. You may:
    1. Decide to keep your pregnancy confidential;
    2. Inform your supervisor and/or EHS; or
    3. Inform EHS and formally declare your pregnancy.

Informing your supervisor and EHS, and formally declaring your pregnancy is the most prudent course of action. It provides maximum protection for the developing embryo/fetus.

Before you declare your pregnancy, you should talk to your supervisor and/or a member of the EHS staff to discuss what a declaration of pregnancy would mean specifically for you and your job status.

The choice whether to disclose this information is completely VOLUNTARY. You may directly contact EHS regarding any questions about occupational exposure and pregnancy. It is not necessary to obtain permission from your supervisor to do so. Any information provided to EHS regarding your pregnancy will be kept confidential.

You have the option of formally declaring your pregnancy. If you do so, measures will be taken to limit the dose to the embryo/fetus to 0.5 rem during the entire pregnancy.

Procedures:

Pregnancy Declaration:
If you choose to declare your pregnancy, you must do so in writing. The declaration may be performed at any time during the pregnancy. EHS will provide the appropriate form to be completed.

The Voluntary Declaration Form must be completed, signed and returned to EHS. By signing this form you state that you have been advised of the potential health risks to the embryo/fetus associated with radiation exposure and have been advised of the NRC requirements to limit the dose to the embryo/fetus to 500 mrem for the entire gestation period. Before signing and returning the form you should have any questions concerning this information answered to your satisfaction.

After a written declaration is filed, instruction will be provided and may include limitation of normal job functions if they could cause you to receive more than 0.5 rem. This may mean that, if you declare your pregnancy the University may not permit you to do some of your normal job functions if those functions will cause you to receive more than 0.5 rem and you may not be able to have some emergency response responsibilities. In most cases, however, you can continue in your present job with no change and still meet the dose limit for the embryo/fetus. Any necessary modification of your duties will be discussed with you, the Radiation Safety Office and departmental supervisor.

A declaration of pregnancy may be withdrawn at any time. If it is withdrawn, the lower dose limit will no longer apply.

You may ask your supervisor for a job that does not involve any exposure to occupational radiation dose, but the University is not obligated to provide you with a job involving no radiation exposure. The decision on what level of risk to accept is yours.

Related Information:

Voluntary Declaration of Pregnancy/Declaration Withdrawal Forms
NRC Regulatory Guide 8.13 - Instructions Concerning Prenatal Radiation Exposure

SEC-009, Utilization of Radioactive Materials

Policy Background:

This is the first version of this policy.

Major Category: Safety, Security and Environmental Quality
Approved by, Date: Executive Vice President and Chief Operating Officer, 08/01/2005
Revision History: Updated 9/27/11, 8/25/2008.