RE: Children in Research Areas

["Sandy Perle" <sandyfl@earthlink.net>]

Quang Le stated the following:

> My question: If you let a child (<18) into the "restricted area" (for
> whatever reason!), my understanding, by reading the NUREG then, is that the
> child is subject to the occ. dose limit for minors (10% of adult limits).
> Is my interpretation correct? Any comment would be appreciated.

If this interpretation is valid, and the NRC does in fact mean this, 
then the dose allowed is significantly higher than if the public dose 
limits are imposed. The dose for a minor would be 500 mrem/year 
instead of the more limiting dose of 100 mrem/year for a member of 
the general public.

Since the NRC has stated that individuals who are expected to exceed 
100 mrem/year, should be considered "occupational workers" and 
receive some level of training, I question the interpretation above. 
On the one hand, the limiting factor is the dose to be received and 
on the other, it's the area to be accessed. In my opinion, the Q&A 
prior to the implementation of the revised 10CFR20 is no longer 
valid, with the issuance of the more recent training requirements, 
whereby the occupational worker has been redefined based on the dose 
to be received, and not the area accessed or job accountabilities.


------------------
Sandy Perle
Technical Director
ICN Dosimetry Division
Costa Mesa, CA 92626
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sandyfl@earthlink.net
sperle@icnpharm.com

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