restricted area == rad prot prog

["Les Slaback, Health Physics" <SLABACK@micf.nist.gov>]

For an NRC licensee the situation is relatively simple.... Def of restricted
area: an area, access to which is limited by the licensee for the purpose of
protecting individuals against undue risks from exposure to radiation and
radioactive materials.

That is, if you have to have a rad prot program to control or limit exposures,
presumably involveing limiting access in at least some limited way,
the the area addressed by that program is a RESTRICTED AREA.
If the risks are sufficiently small that access does not need to be limited
then it is an unrestricted area and a rad prot prog for that area is not
required.
Doing envir surveys and monitoring does not make an area a restricted area.
So just because your rad prot program has activities in an area that aspect
of the program does not impart a restricted area status to that area.

So what this train of thought leads to is:
If an area meets the definition of a restricted area that is where you must
have a radiation protection program, and it is the ONLY area where such a
program is required.

Hence (to return to my previous comment about training) the training
requirement is most appropriately linked to the restricted area concept.

Note that 'access is limited' can mean the most minimal sort of limit, e.g.,
stopping to read a sign imparting mandatory information.  It does not
have to mean barriers or physical controls on access, although NucPwr
facilities usually think along those lines.  Materials licensees certainly
do not.

I have seen and heard words from NRC types that interpret restricted areain
a much more restrictive fashion, e.g., just where you have Radiation Areas,
HRAs, etc.  I have also seen them interpret the phrase 'limit access'
in a more strict fashion, e.g., forceable barrier (albeit in the context
of interpreting 'Controlled Area').

But the above discussion is attractive (a least to me) because it links
the basic definition of restricted area to what the rad prot program covers
in terms of controlling occupational dose.  Occupational dose that occurs
outside a restricted area, and hence outside the coverage of the rad prot
program, is another can of worms linked to the deficient definition of
occupational dose.  If the dose occurs outside the area covered by the rad
prot program, and hence outside the Justification and Optimization processes
of the licensee, how can it be classed as dose subject to the occupational
dose limits?

SLABACK@MICF.NIST.GOV
   ...a little risk, like a bit of spice, adds flavor to life