dust mask usage

[Les Slaback <lester.slaback@nist.gov>]

Regarding the proposed changes to the NRC rule, note also that this proposal explicitly expands the coverage of the NRC rule to any respirator usage for essentially any purpose in a licensed area, regardless of the intended purpose of that usage [unless you can explicitly demonstrate no, i.e., zero, licensed material involvement.]  So if you are an NRC licensee you had best have an NRC approved respiratory protection program in place.  There are no waivers for 'ALARA' usage at low concentrations, even if you have a compliant OSHA program.

As far as I know the rule is still being finalized so changes could still happen.

Opinion:  Why does NRC need a section on respiratory protection at all?  They have an agreement to enforce OSHA rules, and can issue citations based on 29CFR.  Internal exposures are largely a trivial portion of the occupational dose commitment for the vast majority of workers.  Is not this whole section a waste of NRC  regulatory resources?

Just thought it was time to stir things up again.  :-)

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
100 Bureau Dr.  STOP 3543 
Gaithersburg, MD  20899-3543 
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