Answer to Question #994 Submitted to "Ask the Experts"

How can I keep a useful exposure history database without social security numbers? I am the assistant radiation safety officer at a major university. Recently, US House Bill 1043 passed into law and has prompted some of our new isotope users not to release their social security numbers to our office for purposes of dosimetry record keeping. Having read HB 1043, I believe that some persons are making a fundamental misinterpretation of the gist of the law. Some feel that they are not required to release their social security numbers for ANY purpose. As far as I can tell, the gist of the law is that state agencies cannot release a person's social security number without prior written consent from the individual concerned. State agencies can still require social security numbers for employment purposes, driver's licenses, college grades and degrees, etc. I have an extensive database containing exposure histories for persons associated with the university in the past based on social security numbers. How in the world can I maintain a useful database without social security numbers?

Obviously, there are many potential problems that may result from not having an intrinsic identifier associated with a radiation worker's exposure history. For example, many of the requests for exposure history by women who worked at the university during college have a different last name than the original maiden name of the person in question. Also, there have been requests which contain variations of the first name. The only unchanging unambiguous identfier is the social security number in these cases. The date of birth is not unique when there is an exposure history record for approximately 15,000 persons and certainly is of no help when browsing a database for a person whose last name has changed. Issuing a manufactured number would probably be very ineffective as well, since the person would then have to memorize the "dummy number" and send it along with the request for exposure history.

Have you had any similar experiences come to light? If so, what is your interpretation or opinion concerning this "potential problem?"

Daniel L. Van Gent

I agree that the social security number (SSN) of the employee is the best identifier for tracking personnel exposures. However, with the growing use of the Internet and the increased concern about privacy, I understand the reluctance of some people to release their SSN for any reason.

You are wise to anticipate added restrictions to the use of SSNs for personal identification. For that reason, an ideal tracking system would use a unique identifier that would not compromise an individual's right to privacy. However, at the present time there is no other unique identifier that can replace the practicality of using the SSN. The dose record is a national resource that is used by many licensees as well as regulatory agencies. Radiation workers are a very mobile population; they move frequently from job to job. Therefore, any identifier has to be unique to the worker and, at the same time, independent of the licensee. Overexposure reports filed with the US Nuclear Regulatory Commission require the SSN or some other nationally identifying number, such as a passport number, of the person who was exposed. All radiation workers have a SSN, but may not have any other nationally identifying number. Some state agencies continue to use SSNs as identifiers for driver's licenses, employment records, college transcripts, and other purposes.

No solution has been found that adequately replaces the SSN with another identifier for national tracking purposes. Besides, if another nationally identifying number were created, the issue of privacy for the individual would remain a concern.

Betty Ann Torres, MS Health Physicist