Enclosure 

1 

Advisory Committee on the Medical Uses of Isotopes (ACMUI) 

Fingerprint Efficiency Subcommittee Report 

August 1, 2008

Team Members: R. Lieto, M.S., B. Thomadsen, Ph.D., R. J. Vetter, Ph.D., Chair 

Charge: The Subcommittee was charged with examining fingerprinting options for improving 

efficiency & reducing costs for licensees. This report briefly describes optional mechanisms for 

licensees to use in satisfying the requirement to submit fingerprints of workers who need access 

to radioactive materials that require increased controls. The report provides options for 

improving efficiency and reducing cost without judging which option(s) might be best for a 

particular licensee. Small licensees might find that the best option for them is not the best 

option for larger licensees and vice versa. Also, the technology used by local law enforcement 

or the licensee's own Security work unit may dictate which option a licensee uses. Finally, 

suggestions are provided on actions licensees may take to decrease costs and increase 

efficiency and actions the NRC should consider to remove obstacles for licensees. 

Methods: The Subcommittee discussed numerous processing and fingerprinting options with 

security specialists and members of local law enforcement. Comments were also received from 

a number of licensees. Processing options considered were: processing fingerprints in-house, 

using an outside vendor who could collect fingerprints and send them to NRC, and using law 

enforcement either on-site or at law enforcement headquarters. 

Costs (excluding fingerprinting labor and employee time away from work):

The cost of fingerprinting by local law enforcement or by a vendor is usually a per-person fixed 

price. Licensees who want to perform their own fingerprinting in-house need to purchase 

equipment to do so. The cost of equipment and supplies is dependent on the sophistication of 

the process selected. Following are approximate costs for equipment and supplies for three 

common processes. 

 

1. Hand-written, hand rolled: 

Fingerprinting station $150 

Hand cleaner $ 40

Total ~ $200 

2. Computer-printed, hand rolled: 

Fingerprinting station $150 

Hand cleaner $ 50 

Laptop computer $600 

Laser printer $400 

Misc. connectors $ 50 

Equipment cart $200

Total ~ $1500 

3. Automated Fingerprint Identification System (AFIS): ~ $30,000 

Printrak (Motorola) 

Cogent (Motorola) 

Morpho 

NEC 
Enclosure 

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Outcomes:

Processing Options: Internal processing (i.e. fingerprinting in-house) is convenient, allows 

complete control of scheduling and rapid re-printing of unclassifiable fingerprints when using an 

AFIS and is good for ongoing fingerprinting needs. However, it requires registration with State 

Department of Public Safety, and currently, cards could be rejected by FBI for not being 

processed by an “official” law enforcement agency. Vendor processing offers guaranteed 

quality, and information privacy liability is passed on to the vendor. Most vendors use AFIS, so 

processing is fast. However, it may be expensive depending on the number of persons to be 

fingerprinted. Most law enforcement agencies use AFIS so processing is fast, and information 

privacy liability is passed to the agency. However, current jurisdictional issues require that the 

fingerprints be submitted to NRC rather than directly to the FBI. 

Options for processing fingerprints in-house: Fingerprinting with hand-written, hand-rolled 

fingerprint cards is fast and inexpensive (e.g. Fingerprinting station costs approximately $200). 

No electronic technology is required and technician training is minimal. However, inaccurate or 

illegible entries and poorly rolled fingerprints may result in a high rate of rejected (unclassifiable) 

cards. Computer-printed, hand-rolled fingerprint cards offer fast generation of multiple cards, 

accurate and legible entries, standardized abbreviations, a permanent data record, and less risk 

of unclassifiable cards. Fingerprints still can be poorly rolled, however. An AFIS provides fast 

generation of multiple cards, accurate and legible entries, standardized abbreviations, a 

permanent data record, and the possibility of electronic submission. The system quickly 

identifies unclassifiable fingerprints, so employees can be reprinted on the spot. However, AFIS 

is expensive and requires regular calibration and upgrades and network requirements to NRC, 

FBI, or State Department of Public Safety. 

IV. Summary

1. Best price: Hand written, hand rolled, internal processing 

2. Best quality: AFIS, vendor processing 

3. Most Convenient to use: AFIS, internal processing 

4. Highest customer throughput: Computer printed, hand rolled, internal or vendor 

 processing 

5. Highest data security: Hand written, hand rolled, internal processing 

6. Govt. preference: AFIS, Law Enforcement processing 

7. Govt. processing: AFIS, Law Enforcement processing 

8. Best search capabilities: AFIS, internal processing 

How to Decrease Costs and Increase Efficiency

1. Actions that licensees should consider: 

a. Use fingerprints submitted under other state or federal regulatory requirements such 

as select agents or medical licensing (see Attachment 3, Par. 3 of order) 

b. Reduce the number of people approved for unescorted access by pairing up or by 

designating a few people to escort others or to perform the irradiations. This may not 

be practical for all licensees, especially for blood banks or transfusion medicine 

laboratories that operate 24/7 but may be workable in a research setting. 

c. Isolate irradiator in a small room to reduce the number of people who need access. 

In small blood banks and hospital transfusion medicine departments, this may not 

increase safety if the laboratory is already secured. In large transfusion medicine 

departments it may be justifiable but still costly. 
Enclosure 

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d. Research facilities establish a core facility where samples are irradiated by a small 

staff. This option would be expensive if staff must be hired for this purpose only but 

may reduce costs if incorporated into a few designated technologists’ duties. 

e. Order allows relaxing certain requirements including requesting that certain parts of 

order not apply to a specific individual, e.g. someone with an active federal security 

clearance. However, this may be rarely applicable, and the paperwork may be 

onerous. (See Attachment 3, Par. 3 of order). 

f. If employees must travel some distance, e.g. 20 miles, for fingerprinting, arrange for 

licensee Security or local law enforcement to do the fingerprinting on site. 

2. Actions that NRC or others should consider to remove obstacles for licensees: 

a. Licensees have experienced many unclassifiable fingerprint cards (some say as high 

as 25%). However, when fingerprinting physicians for licensing purposes, they 

seldom experience unclassifiable cards submitted to FBI through local or state law 

enforcement. Thus, it appears that NRC’s handling of fingerprint cards causes many 

unclassifiable errors. The NRC should address jurisdictional issues to allow 

licensees to submit directly to the FBI which would decrease opportunities to 

degrade the quality of fingerprint cards and may increase the number of acceptable 

agencies or vendors that provide this service. The NRC should also more 

specifically identify acceptable agencies and vendors to facilitate fingerprinting. The 

list could be referenced on the NRC website. 

b. The NRC should address portability of results, i.e. transfer of trustworthy and 

reliability (T&R) determinations, from one licensee to another to avoid the additional 

cost associated with repeating the T&R determination including fingerprinting. This 

process could be analogous to exposure history requests. Alternatively, the NRC 

could establish a national registry that would allow T&R radiation workers to transfer 

to another licensee without repeating the fingerprinting and criminal records check.