RE: Question about 10CFR20.1903

["Daren Perrero" <dmperrero@email.msn.com>]

In Bob Hite's message he asks about the exemptions listed in the Federal
Regulations regarding posting.  For convenience I thought I would include
them here.
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§20.1903 Exceptions to posting requirements.
(a) A licensee is not required to post caution signs in areas or rooms
containing radioactive materials for periods of less than 8 hours, if each
of the following conditions is met:

(1) The materials are constantly attended during these periods by an
individual who takes the precautions necessary to prevent the exposure of
individuals to radiation or radioactive materials in excess of the limits
established in this part; and

(2) The area or room is subject to the licensee's control.

(b) Rooms or other areas in hospitals that are occupied by patients are not
required to be posted with caution signs pursuant to §20.1902 provided that
the patient could be released from licensee control pursuant to §35.75 of
this chapter.

(c) A room or area is not required to be posted with a caution sign because
of the presence of a sealed source provided the radiation level at 30
centimeters from the surface of the source container or housing does not
exceed 0.005 rem (0.05 mSv) per hour.

[56 FR 23401, May 21, 1991, as amended at 57 FR 39357, Aug. 31, 1992; 62 FR
4133, Jan. 29, 1997]
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I read this as saying:  if someone knowledgeable has direct physical
surveillance/control over the RAM and the work area OR  if a patient
undergoing a RAM treatment is involved that does not have to be hospitalized
OR if you only have sealed sources that are shielded or don't have enough
activity to give off 5 mR/h  THEN you don't need to post a sign in the room,
provided the time period of question doesn't last longer than 8 hours in the
area under concern.

Of course these exceptions come under further question if other sections of
the regulations have a more specific requirement. (Like when you do
radiography, the posting requirement in those regs will take precedent.)

Daren Perrero
dmperrero@email.msn.com
I'm with the government, I'm here to help you....