Question 418: This question refers to the answer to
Question 91 in �.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 �.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 �.1703?
Discussion: If the answer to these questions is that
�.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).