United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

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

Page Last Reviewed/Updated Thursday, March 29, 2012