U.S. Nuclear Regulatory Commission

Request for Clarification of Guidance Regarding Physicians Determination for Physical Qualification of Respiratory Equipment Users

HPPOS-103 PDR-9111210235

Title: Request for Clarification of Guidance Regarding

Physicians Determination for Physical Qualification of

Respiratory Equipment Users

See the memorandum from D. A. Allison to M. M. Shanbaky

dated July 19, 1985. This memo states that physicians need

not sign all forms regarding physical fitness. But, the

physician should be involved in the supervision of the

fitness program, the review of overall results and

individual cases that fall outside certain physical

parameters, and the supervision of personnel performing the

tests. Simply establishing the program with no further

involvement is not adequate. 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 contains a

related topic.

In regards to determining compliance with the 10 CFR 20.103

(c) (2) requirement of who physically signs "fitness"

forms, the intent is to have physicians screen individuals

for health problems prior to respirator use. An acceptable

compliance situation, however, could involve a trained

nurse who physically administers medical testing and

documents and signs the required forms. This situation is

acceptable provided the results of the tests are within a

range established and approved by a physician, and the

physician agrees to retain full responsibility. If the

results of the physical tests fall outside the acceptable

range, the individual's case should be referred to the

physician for more direct attention and testing. [Note:

The above 10 CFR 20.103 (c) (2) requirement is now found in

10 CFR 20.1703 (a) (3).]

Each form does not necessarily need to be signed by a

physician; however, the physician should be involved in the

supervision of the fitness determination program.

Physician supervision of the program is indicated by the

review of overall results, the review of individual cases

that fall outside established ranges, and the general

supervision of personnel actually performing the physical

assessments. Simply establishing acceptable ranges for the

tests, with no further involvement, is not adequate.

Regulatory references: 10 CFR 20.103, 10 CFR 20.1703,

Regulatory Guide 8.15, NUREG-0041

Subject codes: 8.10

Applicability: All