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Respiratory Protection
(This is a resend of this posting. I did not see it appear on RADSAFE
after sending it last Friday. I apologise if it is in fact a duplicate.)
In the 17 July proposed revision of Subpart H is "All licensees who
possess radioactive material in a form that requires a respiratory
protection program are identified during the license application,
amendment, or renewal process." This is used to justify the useful
elimination of a notification requirement. This is a somewhat ominous, but
probably innocuous, statement. But the overall thrust of this proposal,
and the related draft reg guide, is to explicitly cover virtually any use
of a respirator in a licensed facility.
Even if the usage purpose is strictly non-radiological the reg guide is
explicit that Subpart H is required unless you can prove no intake
involvement. Assuming a zero protection factor will not do it. These
proposals offer some simplifications to the rules, but primarily remove
ambiguity on the part of licensees relating to past interpretations of the
NRC.
If you ***possess*** a respirator I suggest that these proposals should be
reviewed.
Questions: OSHA recently revised its respiratory rules (29CFR1910.134).
1. What is the benefit of subpart H over 29CFR?
2. Is this duplicate regulation? If you implement 10CFR can you ignore
29CFR, or vice-a-versa?
3. Do the smaller licensees get their safety departments to implement
Subpart H along with their OSHA program? Despite similarities they are
different.
4. Do masks in medical situations qualify as respiratory protection so that
presumably all medical licensees would have a Subpart H program?
Opinion: For materials licensees (i.e., all but power reactors) Subpart H
is a great inducement to eliminate any sort of respiratory protection in
your facility, even for 'ALARA' uses.
No, I am not a shill for my friends down the road. Just stirring the pot.
Disclaimer: the above are the personal musings of the author, and do not
represent any past, present, or future position of NIST, the U.S. government,
or anyone else who might think that they are in a position of authority.
Lester Slaback, Jr. [Lester.Slaback@NIST.GOV]
NBSR Health Physics
Center for Neutron Research
NIST
Gaithersburg, MD 20899
301 975-5810
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