Question 387: In evaluating the use of respirators to
limit intakes, in addition to determining the total
effective dose equivalent (TEDE), should the evaluation and
subsequent decision on whether to use respirators also
consider industrial safety hazards associated with wearing
respirators? For example, added effort increasing the
probability of heat stress, limited range of vision while
climbing, or difficulty of maneuvering readily while
working in confined spaces due to wearing a respirator may
pose potentially greater safety risks than does the
potential dose from uptake of airborne radioactive material
to which an individual might be exposed by not wearing a
respirator.
Answer: 10 CFR 20.1702 provides for the use of
respirators consistent with maintaining the TEDE as low as
is reasonably achievable. A reduction in the TEDE for a
worker is not reasonably achievable if an attendant
increase in the worker's industrial health and safety risk
would exceed the benefit to be obtained by the reduction in
the radiation risk associated with the reduction in the
TEDE. The NRC has never maintained that application of the
ALARA principle requires ignoring factors other than
radiation that may have an adverse impact on public health
and safety. (References: 10 CFR 20.1702, 10 CFR 20.1703).