Instructions to Workers: 10 CFR Part 19 & Form 3

Introduction

10 CFR Part 19 is the worker-facing side of the NRC's radiation program: the notices a licensee must post, the instructions workers must receive, and the dose reports they are owed. Part 20 tells you the dose limits; Part 19 is how those protections actually reach the person standing next to the source.

It is also one of the most quietly common gaps at inspection — not because it is hard, but because it is easy to assume it is handled. Dosimetry is running, dose limits are met, and everyone forgets that the NRC Form 3 on the wall is three revisions old, that the new hire's radiation instruction was never documented, or that monitored workers never received last year's dose report. None of those are exotic failures. All of them are citable. ^{1, 3}

This guide walks through what Part 19 requires — posting under 19.11, instruction under 19.12, and dose reporting under 19.13 — how it connects to Part 20's limits and quantities, and how a radiation safety officer builds a documented program that holds up. DRPS supports this work through its radiation safety officer and radiation safety training services across Florida, Maryland, Virginia, Washington DC, California, Nevada, Pennsylvania, New York, New Jersey, and Delaware.

Topic Explanation

What Part 19 covers

The full title is "Notices, Instructions and Reports to Workers: Inspection and Investigations." It establishes the obligations a licensee owes to individuals who work with, or in the vicinity of, licensed radioactive material, and it preserves workers' rights in the NRC inspection process. The core operational sections are: ¹

• 19.11 — Posting of notices to workers. What must be displayed where workers can see it, including NRC Form 3.
• 19.12 — Instruction to workers. What workers must be taught, and who must be taught.
• 19.13 — Notifications and reports to individuals. What dose information workers receive, and when.
• 19.14–19.16 — Inspections. Workers' rights to request an inspection, to accompany inspectors, and protection from discrimination for raising safety concerns.

Part 19 is deliberately worker-centered. Where Part 20 is about numbers and limits, Part 19 is about information and rights — making sure the people exposed know the hazards, know their protections, and can see their own dose. ^{1, 2}

Why it matters beyond compliance

A worker who understands the hazard collimates the fluoroscope, steps back from the source, and wears the dosimeter correctly. Part 19 instruction is not a box to check — it is the mechanism by which an ALARA culture is built, because informed workers make the small decisions that keep dose low. That is why the instruction requirement is tied directly to the potential for meaningful dose. For the program that surrounds it, see our guides on building an ALARA program and the radiation safety training program. ^{1, 6}

Key Technical Principles

Posting — 10 CFR 19.11

Section 19.11 requires the licensee to post current copies of specified documents where workers pass to and from licensed activities, conspicuously, and to replace any that are defaced or altered. What must be posted includes the regulations in Parts 19 and 20, the license and its conditions (or a notice of where they may be examined), the operating procedures applicable to licensed activities, any notice of violation and response, and NRC Form 3, "Notice to Employees." ^{1, 3}

NRC Form 3 summarizes, in plain language, workers' rights and licensees' responsibilities. The NRC periodically revises it — recent revisions were issued in 2024 and a further revised version was made available in 2025 — and 19.11 requires that when the Commission issues a revised Form 3, the licensee replace the posted version within 30 days of receiving it. Posting an outdated Form 3, or none at all, is a frequent and easily avoided citation. ^{3, 4}

Instruction — 10 CFR 19.12

Section 19.12 sets both a threshold and a curriculum. The threshold: all individuals who in the course of employment are likely to receive an occupational dose in excess of 100 mrem (1 mSv) in a year must be instructed. The curriculum, which must be commensurate with the potential radiological health hazards in the workplace, requires that such workers be: ¹

• kept informed of the storage, transfer, or use of radioactive material;
• instructed in the health protection problems associated with exposure, in precautions and procedures to minimize dose, and in the purposes and functions of protective devices;
• instructed in, and required to observe, the applicable NRC regulations and license provisions for their protection;
• instructed to report promptly to the licensee any condition that may cause a violation or unnecessary exposure; and
• advised of the radiation exposure reports they may request under 19.13.

The NRC's Regulatory Guides operationalize this content: Regulatory Guide 8.29 covers instruction on the risks of occupational radiation exposure, and Regulatory Guide 8.13 covers instruction concerning prenatal radiation exposure for workers who may declare a pregnancy. ^{5, 6}

Reporting — 10 CFR 19.13

Section 19.13 governs the dose information a worker receives. A monitored worker must be furnished an annual written report of their occupational dose. A worker may also request their dose at any time and must receive a written report within 30 days of the request or within 30 days after the dose has been determined, whichever is later; a similar report is due at termination of employment involving exposure. If the licensee determines that a worker's dose may have exceeded a limit, it must notify the worker promptly. ^{1, 7}

These reports use Part 20 quantities, which is where the two rules meet. The relevant summed quantity is the total effective dose equivalent (TEDE) — the external deep-dose equivalent plus the committed effective dose equivalent from any intake:

Consider a nuclear-medicine technologist with an annual external deep-dose equivalent of 8 mSv and a committed effective dose equivalent of 2 mSv from a minor intake:

That result is compared to the occupational limit in 10 CFR 20.1201 of 50 mSv (5 rem) TEDE per year, so this worker is at 20% of the annual limit. Many licensees set an ALARA investigation level well below the limit — for example, 10% of the annual limit — so a 10 mSv result would prompt a documented ALARA review even though it is far under 50 mSv. And any worker who has declared a pregnancy is subject to the more protective embryo/fetus limit of 5 mSv (0.5 rem) over the gestation under 10 CFR 20.1208 — precisely the scenario Regulatory Guide 8.13 instruction is meant to support. ^{2, 5}

The three obligations at a glance

Clinical Impact

The new-hire and annual-refresher moment

For a medical facility, Part 19 shows up most concretely at onboarding and at the annual refresher. A new nuclear-medicine technologist, interventional nurse, or fluoroscopy operator who is likely to exceed 1 mSv/yr must receive documented instruction before working with sources. The RSO's training record — who was trained, on what, and when — is the evidence that 19.12 was met. An undocumented verbal briefing is, for inspection purposes, no briefing at all. ^{1, 6}

The declared-pregnant worker

Part 19 instruction is the vehicle for one of the most sensitive conversations in radiation safety. A worker cannot make an informed decision about declaring a pregnancy — which invokes the 5 mSv gestational limit — unless she has been instructed on prenatal radiation risk, which is exactly what Regulatory Guide 8.13 provides. The instruction has to happen before the decision, not after. For the operational side, see our guide on the pregnant radiation worker. ^{2, 5}

The dose report nobody sent

The 19.13 annual report is easy to overlook because dosimetry vendors deliver dose data to the RSO, not to each worker. The obligation to pass that information to the individual — annually, and on request — is separate, and it is frequently the missing piece. A program that automatically issues each monitored worker their annual dose summary closes a gap that inspectors routinely probe. ^{1, 7}

Practical Optimization Tips

A defensible Part 19 program is mostly about documentation discipline.

1. Fix the posting board

Confirm the posted NRC Form 3 is the current version, and put a standing process in place to swap it within 30 days whenever the NRC issues a revision. Post the regulations, the license (or a notice of where to examine it), and current operating procedures alongside it, conspicuously, on the path workers travel. ^{1, 3}

2. Make instruction a documented event

Tie 19.12 instruction to onboarding and to an annual refresher. Use Regulatory Guides 8.29 and 8.13 to shape the content, and capture attendance, date, and topics in a signed record. Scale the depth to the hazard — a PET technologist needs more than a receptionist. ^{1, 5, 6}

3. Set the instruction threshold correctly

Identify which staff are "likely to receive > 1 mSv/yr" and therefore must be instructed. Base it on realistic workload, not worst-case assumptions, and revisit it when duties change. ¹

4. Automate the annual dose report

Build a routine that delivers each monitored worker their annual TEDE, and a fast path to answer an on-request or termination report within 30 days. Keep proof that the report was provided. ^{1, 7}

5. Protect the inspection rights

Ensure workers know they may request an NRC inspection and are protected from retaliation for raising safety concerns (19.14–19.16). This is both a legal obligation and a sign of a healthy safety culture. ¹

Common pitfalls to avoid

• An outdated or missing NRC Form 3. The single most avoidable Part 19 citation.
• Verbal-only instruction. Without a signed, dated record, the instruction cannot be demonstrated.
• Confusing dosimetry with reporting. Receiving dose data as the RSO is not the same as reporting it to the worker.
• A stale instruction list. Staff whose duties changed may have crossed the 1 mSv threshold without being added.
• Assuming Agreement-State rules differ in substance. They mirror Part 19; the obligations still apply.

Regulatory Considerations

Part 19 is an NRC regulation, but its substance reaches every medical facility that uses radioactive material — directly for NRC licensees, and through compatible state rules for Agreement-State licensees. ¹

Key frameworks:

• 10 CFR Part 19 — the posting, instruction, reporting, and inspection-rights requirements themselves. ¹
• 10 CFR Part 20 — the dose limits and quantities (TEDE, the 50 mSv occupational limit, the 5 mSv declared-pregnancy limit, monitoring thresholds) that Part 19's instruction and reports reference. ²
• NRC Form 3, Notice to Employees — the required worker posting, kept current. ^{3, 4}
• NRC Regulatory Guides 8.29 and 8.13 — the content guidance for occupational-risk and prenatal-exposure instruction. ^{5, 6}

Jurisdiction depends on location. Of the states DRPS serves, Florida, Maryland, Virginia, California, Nevada, Pennsylvania, New York, and New Jersey are NRC Agreement States that administer their own worker-notification and instruction rules compatible with Part 19, while Washington DC and Delaware are regulated directly by the NRC. A facility should confirm whether its obligations run to the NRC or to a state program and follow that program's equivalent of Part 19. For related preparation, see our guide on preparing for an NRC inspection. ^{1, 2}

Frequently Asked Questions (FAQs)

What is 10 CFR Part 19?

10 CFR Part 19, "Notices, Instructions and Reports to Workers: Inspection and Investigations," is the NRC regulation defining the worker-facing obligations of a licensee. It requires posting notices such as NRC Form 3, instructing workers about radiation and their protections, providing workers their radiation dose reports, and preserving workers' rights to request an NRC inspection.

Who must be instructed under 10 CFR 19.12?

All individuals who are likely to receive, in a year, an occupational dose in excess of 100 mrem (1 mSv) must be instructed. The instruction covers the health risks of radiation, precautions to minimize dose, the purpose and use of protective devices, the applicable regulations and license conditions, the duty to report unsafe conditions, and the dose reports a worker may request.

What is NRC Form 3?

NRC Form 3, "Notice to Employees," is a posting that summarizes workers' rights and licensees' responsibilities under NRC regulations. Under 10 CFR 19.11, licensees must post the current version conspicuously where workers pass to and from licensed activities, and replace a superseded version within 30 days of receiving the revised form.

What dose reports are workers entitled to?

Under 10 CFR 19.13, a monitored worker must receive an annual written report of their occupational dose. A worker may also request their current-year dose at any time and must be given a written report within 30 days of the request or after the dose is determined, and a report at termination. If a worker's dose may have exceeded a limit, the licensee must notify them promptly.

Does Part 19 apply to Agreement State licensees?

The NRC's Part 19 applies to NRC licensees, but Agreement States adopt compatible worker-notification, instruction, and reporting requirements in their own radiation-control rules. A facility in an Agreement State follows the equivalent state provisions, which mirror the substance of Part 19 and Part 20.

How does Part 19 relate to Part 20?

Part 20 sets the dose limits and the monitoring and record requirements; Part 19 is how those obligations reach the worker — posting, instruction, and reporting. Part 19's instruction threshold and dose reports reference Part 20 quantities such as the total effective dose equivalent and the occupational dose limits.

Why is Part 19 a common inspection finding?

Because it is easy to assume it is handled. Facilities focus on dosimetry and dose limits and overlook a missing or outdated NRC Form 3, undocumented worker instruction, or an annual dose report that was never issued. These are straightforward to fix but frequently cited, so a documented Part 19 program is worth confirming before an inspection.

Key Takeaways

• Part 19 is the worker-facing rule. Part 20 sets the limits; Part 19 posts the notices, instructs the workers, and reports the dose.
• Post the current NRC Form 3. It must be conspicuous and replaced within 30 days when the NRC issues a revision — the most avoidable citation in the part.
• Instruct everyone likely to exceed 1 mSv/yr. The 100 mrem (1 mSv) threshold triggers documented instruction on risks, precautions, protective devices, and regulations.
• Report dose to the individual. Monitored workers get an annual report; requests and terminations are answered within 30 days; possible over-limit dose triggers prompt notice.
• The quantities are Part 20's. TEDE = DDE + CEDE, compared to the 50 mSv occupational limit and the 5 mSv declared-pregnancy limit.
• Document everything. For Part 19, an undocumented action is, at inspection, an action that did not happen.

Conclusion

Part 19 is not the glamorous part of a radiation safety program, but it is the part inspectors can check in five minutes and the part that most directly touches the worker. A current NRC Form 3, a documented instruction program pegged to the 1 mSv threshold, and an annual dose report that actually reaches each monitored worker are not difficult to maintain — they are just easy to forget.

The facilities that never get cited on Part 19 treat it as a standing process, not a scramble before an inspection: the posting board is current, instruction is a documented onboarding and refresher event, and dose reporting is automated. Done that way, Part 19 stops being an audit risk and becomes what it was meant to be — the mechanism that keeps workers informed, protected, and part of the ALARA culture.

How DRPS Can Help

Diagnostic Radiation Physics Services helps facilities build and document the worker-facing side of their radiation safety program: NRC Form 3 and posting review, Part 19 instruction content aligned with Regulatory Guides 8.29 and 8.13, worker dose-reporting workflows, and inspection readiness — delivered through radiation safety officer support, radiation safety training, and medical physicist consulting.

DRPS supports facilities across our service locations, including Florida, Maryland, Virginia, Washington DC, California, Nevada, New York, Pennsylvania, New Jersey, and Delaware.

Part 19 is the cheapest inspection risk to close — and closing it means workers actually know their hazards, their protections, and their dose.

Related Resources

• Building an ALARA program
• Radiation safety training program
• The pregnant radiation worker
• Preparing for an NRC inspection
• NRC occupational dose limits (Part 20)
• Radiation Safety Officer consulting
• Radiation safety training

References

1. U.S. Nuclear Regulatory Commission. 10 CFR Part 19: Notices, Instructions and Reports to Workers: Inspection and Investigations. ecfr.gov
2. U.S. Nuclear Regulatory Commission. 10 CFR Part 20: Standards for Protection Against Radiation (including §§ 20.1003, 20.1201, 20.1208, 20.1502). ecfr.gov
3. U.S. Nuclear Regulatory Commission. NRC Form 3, "Notice to Employees". nrc.gov
4. U.S. Nuclear Regulatory Commission. Availability of Revised NRC Form 3, "Notice to Employees". Federal Register; 2025. federalregister.gov
5. U.S. Nuclear Regulatory Commission. Regulatory Guide 8.13, Revision 3: Instruction Concerning Prenatal Radiation Exposure. 1999. nrc.gov
6. U.S. Nuclear Regulatory Commission. Regulatory Guide 8.29, Revision 1: Instruction Concerning Risks from Occupational Radiation Exposure. 1996. nrc.gov
7. U.S. Nuclear Regulatory Commission. Regulatory Guide 8.7, Revision 4: Instructions for Recording and Reporting Occupational Radiation Dose Data. nrc.gov
8. U.S. Nuclear Regulatory Commission. Occupational Dose Records, Labeling Containers, and the Total Effective Dose Equivalent. Federal Register; 2007. federalregister.gov
9. U.S. Nuclear Regulatory Commission. 10 CFR Part 35: Medical Use of Byproduct Material. ecfr.gov
10. National Council on Radiation Protection and Measurements. NCRP Report No. 127: Operational Radiation Safety Program. 1998. ncrponline.org