Health Physics Questions and Answers - Question 91

Question 91: As long as no credit is taken for the protection provided by the respiratory protection equipment, the old Part 20, in 10 CFR 20.103 (c), allows licensees to use this equipment without meeting the requirements of 10 CFR 20.103 (c) (1) through 20.103 (c)(4), inclusive. Has this "loophole" in the old Part 20 been closed in the revised Part 20?

Answer: Yes. 10 CFR 20.1703 (a), which contains requirements similar to those in 10 CFR 20.103 (c), imposes these requirements "if a licensee uses respiratory protection equipment to limit intakes," regardless of whether the licensee makes "allowance for this use of respiratory protective equipment in estimating exposures of individuals . . . ."

(Reference: 10 CFR 20.1703)