Question 413: This question refers to the answers to
Questions 66 and 31 under �.1003 and �.1201,
respectively, and to Question 26 (d) under �.1003.
Simply designating an area as a restricted area so you can
control everyone at occupational dose limits is a
perversion of every radiation protection principle
published. Of course, this is just my opinion. I hope NRC
will revise its interpretation of this definition.
For example, a secretary in a nuclear medicine clinic
without any direct person-to-person contact with patients
should not be subject to occupational limits just because
she is in a restricted area. Many other examples could be
cited, and some that are more in the gray area should be
examined carefully. Clearly, there is a significant
population of exposed persons that are not being held to
the proper standard. The following statement refers to the
answer to Question 26 (d) concerning "individual E." In
spite of the definition of occupational dose, mere
geography is not justification for classifying a person as
a radiation worker.
Answer: The questioner appears to object to the
definition of "occupational dose" that states that
"occupational dose means the dose received by an individual
in a restricted area or . . . ." The NRC cannot change
this definition by revising its "interpretation of this
definition." The definition can only be changed by
rulemaking.
While there may have been a lack of clarity in the
referenced answers, our intention is that licensees should
not engage in a practice of "simply designating an area as
a restricted area so you can control everyone at
occupational dose limits." Question 66 asks if a simple
fenced area can qualify as a restricted area and the answer
is yes, provided it is the licensee's purpose to limit
access for the purpose of controlling radiation exposures.
Question 31 asks if students and volunteers (such as
nuclear medicine students and "candy stripers" who
transport nuclear medicine patients or perform volunteer
work in a nuclear medicine department) are subject to
occupational dose limits. The answer to this question is
that these individuals are subject to the occupational dose
limits because, and provided that (as the question
implies), the type of work they are assigned involves
exposure to radiation; it does not matter where (in which
area) they are working Question 26 (d) asks if the
occupational dose limits or public dose limits apply to
"Individual E," a secretary for a radiography company, who
works in a "controlled area" next to a "restricted area"
containing a hot cell. The answer is that the occupational
dose limits apply), again because the type of work assigned
presumably involves exposure to radiation since it must be
performed near the hot cell. (References: 10 CFR 20.1003,
10 CFR 20.1201).