Medical Surveillance for Respirator Users
HPPOS-117 PDR-9111220025
Title: Medical Surveillance for Respirator Users
See the open letter from R. B. Minogue to All Licensees and
Other Interested Persons dated March 14, 1978. This letter
states that the NRC does not require complete physical
examinations of each respirator user, only an initial
medical examination and annual reviews of medical status.
Licensees can obtain proof from contractors that
determinations of medical status were made on contractor
employees. The health physics position was written in the
context of 10 CFR 20.103, but it also applies to "new" 10
CFR 20.1703. HPPOS-061 and HPPOS-103 contain related
discussions.
NRC Regulation 10 CFR 20.103 (c) [or 10 CFR 20.1703 (a)]
permits licensees to make allowance for the use of
respirators provided that the equipment is used as
stipulated in Regulatory Guide (RG) 8.15. Licensees who
make allowance for respirators are required by RG 8.15 to
determine:
"... prior to assignment of any individual to tasks
requiring the use of respirators that such an individual is
physically able to perform the work and use the respiratory
protective equipment. A physician is to determine what
health and physical conditions are pertinent. The medical
status of each respirator user is to be reviewed at least
annually."
The purpose of the requirement is to protect the health of
workers who might have to use respirators. It must be
noted, however, that the NRC does not require a complete
physical examination of each respirator user, only an
initial medical examination and an annual review of medical
status. The physician might or might not require a
physical examination as part of his health assessment.
It is not necessary that the licensees' physician determine
the medical status for the employees of contractors at the
licensee's sites. Licensees can meet the requirement for
making the determinations by obtaining proof from their
contractors that the required examinations of medical
status have been made.
Currently, there is no standard method for medical
surveillance of this type. [Note: ANSI Z88.6-1984 was
developed to provide guidance and information for
physicians and other professionals to determine the
suitability of personnel for respirators.] NUREG-0041,
"Manual of Respiratory Protection Against Airborne
Radioactive Materials," offers suggestions that a
licensee's physician may wish to follow.
Regulatory references: 10 CFR 20.103, 10 CFR 20.1703,
Regulatory Guide 8.15
Subject codes: 8.10
Applicability: All