10CFR20 Subpar H (Respiratory Protection)

[Lester Slaback <Lester.Slaback@NIST.GOV>]

1.  Be aware that the revised rule was published in Sept.
2.  For those who were concerned about the use of respirators where no
credit is taken for the respirator use note that NRC, in their statements
of consideration, specifically exclude this as a basis for using a
respirator in an area with licensed material involvement.  BUT, the
situation is somewhat ambiguous with regard to such incidental exposure.

20.1703 starts " If the licensee assigns or permits the use of respiratory
protection equipment to limit the intake of radioactive material ..... "
The Statements of Consideration define "limit the intake" in a way that
allows incidental exposure.  Note that this term is not defined in the rule
or the reg guide so you better hang on to the S of C.
But, the reg guide requires 1703 "... unless the device is clearly and
exclusively used for protection against non radiological hazards."  Similar
statements appear in the S of C.  
Hence my feeling of ambiguity.

I am privately assured that the intent is to allow incidental exposure for
respirator usage for non radiological purposes, but it would appear that
there is a very thin line between allowed and excluded usage.
This topic was discussed last year when the rule was proposed, and it was
clear that many thought by simply not taking credit they could avoid the
20.1703 program requirement.  I suggest a careful reading of 64FR54543.


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 
301 975-5810 voice
301 921-9847 fax
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