Health Physics Questions and Answers - Question 418

Question 418: This question refers to the answer to Question 91 in §20.1703. Please clarify this response, as indicated below.

(a) Can NRC envision any purpose by which a licensee can use respiratory protection devices without having an approved respiratory protection program, e.g., meeting the provisions of §20.1703?

(b) For instance, work is being conducted where the licensee has determined there is no requirement for respiratory protection but workers prefer to use it anyway. From the workers perspective it is for protection. From the licensees viewpoint, it is simply for peace of mind, with the added benefit of being an ALARA effort. Is this usage subject to §20.1703?

Discussion:

If the answer to these questions is that §20.1703 applies to any conceivable use of respirators then this in essence is a directive for all licensees without approved equipment or an approved program to discard all respiratory protection equipment. It cannot be used even for ALARA purposes at less than DAC levels. It cannot be kept on hand for use in emergency response situations where any protection is useful in initial response conditions. (Note: As a basic presumption, assume that any use of respirators complies with the basic OSHA guidance for medical approval.)

Answer:

(a) The requirements of 10 CFR 20.1703 must be met if the respiratory protection equipment is used to limit intakes of radioactive material pursuant to 10 CFR 20.1702. 10 CFR 20.1703 does not apply if the respiratory protection equipment is used for other purposes (e.g., for protection against harmful dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors that are not radioactive); however, OSHA regulations (which include a requirement for a minimal acceptable respiratory protection program) do apply to most of these uses.

(b) Yes, assuming that the equipment will be used to limit intake, this usage is subject to 10 CFR 20.1703. The use of respiratory protection equipment without meeting the respiratory protection program requirements of 10 CFR 20.1703 (e.g., respirator not properly maintained, poor fit of respirator to wearer, untrained or improperly trained respirator user) can be hazardous to the worker, can lead to a false sense of protection, and cannot be justified on the basis of ALARA, worker peace of mind, or usefulness in an emergency.

(Reference: 10 CFR 20.1703)