U.S. Nuclear Regulatory Commission

Guidance Regarding Physicians' Determination of Physical Qualification of Respiratory Equipment Users

HPPOS-061 PDR-9111210245

Title: Guidance Regarding Physicians' Determination of

Physical Qualification of Respiratory Equipment Users

See the memorandum from W. L. Fisher to R. E. Hall dated

February 1, 1984. This memo states that physicians must

make final determinations of fitness for each respiratory

equipment user. The health physics position was written in

the context of 10 CFR 20.103 (c) (2), but it also applies

to "new" 10 CFR 20.1703 (a) (3).

Although physicians need not administer each test

personally, it is not acceptable for a physician to

establish criteria and have the licensee (or any other

designee) use these criteria to make the determination that

the individual is or is not qualified. The physician may

use a medical designee (such as an office nurse) for

signing the medical approval / denial form for the physician,

as long as the designee's signature is clearly for

administrative convenience and the physician has not

relinquished any responsibility for the fitness

determination.

Regulatory references: 10 CFR 20.103, 10 CFR 20.1703,

Regulatory Guide 8.15, NUREG-0041

Subject codes: 8.10

Applicability: All