Re: Inconsistent dose limits 49 CFR and 10 CFR 20

[MAJ Don Jordan <djordan@osiris.cso.uiuc.edu>]

Pat:  I read your note on inconsistent limits with some interest since a
similar inconsistency exists in 29 CFR (OSHA).  The problem is similar to
the 49 CFR situation in that the last update fo the OSHA 29 CFR 1910.96
was 30 June 1993 with the new 10 CFR 20 being implemented 1 January 1994. 
The change in June 1993 was to correct among other things references to
the old AEC to NRC.  Needless to say OSHA appears to be somewhat behind
the times.  The problem is that NRC only applies to the licensed
activities, while OSHA would appear to have broader application to machine
generated sources.  Although I am tempted to ignore the outdated OSHA
guidance, legally I am not sure this is prudent since some of the old OSHA
dose limits are actually more conservative than the newer NRC limits.  Any
words of wisdom you can provide on this would be greatly appreciated.  

Don Jordan
Air Force Medical Operations Agency
Office of the Surgeon General