Re: DOE Construction & Restoration Projects

[OFFTOWY@aol.com]

I think the view was that the nature of the projects made engineering 
controls impractical and that current guidance allowed for the use of 
respiratory protection under these circumstances, whether performing 
construction, restoration, or normal ops.

Also, note that Article 371 allowed to DOE contractor to change "shalls" to 
"shoulds" with a technical equivalency determination.  Since there are no 
longer any "shalls" in the RCM/RCS, there is no need for this leeway.  The 
requirements exist elsewhere, and the RCS does not carry the "weight" to 
provide exemptions from those requirements.

Lew LaGarde
e-mail - offtowy@aol.com
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