49 CFR Quarterly Limits

[<JHageman@swri.edu>]

Forwarded to:      smtp[radsafe@romulus.ehs.uiuc.edu]
          cc:      
Comments by:       JHageman@Admin@SwRI66

   -------------------------- [Original Message] -------------------------      
Now that I'm carefully reading the new 49 CFR Part 172, I have found what may 
be an inconsistency between it and 10 CFR Part 20. 49 CFR 172.803(b)(1) has a 
dose limit of "12.5 mSv (1.25 rem) in any 3 month period or 50 mSv (5 rem) in 
any 12 month period." These periods may be a sliding periods and may thus be 
much more conservative and in conflict with 10 CFR Part 20, which only has an 
annual (calender year) limit of 5 rem.

I would like some comments on this apparent lack of regulatory consistency.