Part 20 revision

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

60FR36038 (7/13/95) has the long awaited revisions (fixes) to
10CFR20.  Primarily these correct the definitions of public dose
and occupational dose, retain the definition of controlled area,
and change the 10CFR19 training requirement.

Public dose can now be received in restricted areas.

Training is keyed to occupational dose (with a 100 mrem
discriminator) rather than to occupancy in restricted areas
[despite my contrary views which are obviously more insightful].
But the 100 mrem criterion is a reasonable, alternative fix.

Controlled area was proposed to be deleted primarily because of
confusion over its meaning.  Now I see why.  I read the Part 20
definitions of restricted area and unrestricted area to be
mutually exclusive and totally encompassing.  That is any area
must be in one or the other.  An area is either controlled for
the purposes of radiation protection or it is not.  Controlled
area is an area controlled for reasons other than that.  But the
rationale for retaining this definition clearly describes
Controlled Area as a buffer between a restricted area and an
unrestricted area (although another portion of the text agrees
with the former view).  Consult your local regulator to explain
why these two views are consistent.

I am amazed that NRC received only 23 comments on a proposal of
such fundamental interest to the health physics community.  Part
of the reason might have been the lack of a forum such as this to
stir up interest.  NRC has formed some specific BB's to encourage
such comments in the future, but I suspect that common interest
forums like this will be more successful.

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