U.S. Nuclear Regulatory Commission

Footnote g of Appendix A to 10 CFR 20 Concerning Protection Factor for Respirators

HPPOS-225 PDR-9111220136

Title: Footnote g of Appendix A to 10 CFR 20 Concerning

Protection Factor for Respirators

See the letter from L. J. Cunningham to J. A. Kvikstat (3M

Occupational Health and Environmental Safety Division)

dated July 25, 1990. The protection factor assigned in 10

CFR 20 Appendix A (§§20.1001-20.2401) was established for

half mask elastomeric face pieces and is not applicable to

non-elastomeric disposable respirators. Half-mask

disposable respirators capable of providing a good seal are

a recent innovation. Licensees can apply for protection

factors under 10 CFR 20.103 (d). This health physics

position also applies to Paragraph 20.1703 (a) (2) and to

Footnote g in Appendix A of the "new" 10 CFR Part 20

(§§20.1001-20.2401).

Guidance was requested on whether a disposable high

efficiency respirator manufactured by the 3M Company met

the description of a half-mask respirator in Footnote g of

Appendix A to 10 CFR 20 and could be afforded a protection

factor (PF) of 10. NRC stated that PFs were derived from

performance testing and then assigned to classes of

respirators. The PF assigned in Appendix A was established

for half mask elastomeric face pieces and was not

applicable to non-elastomeric disposable respirators. The

"under-chin" specification in Footnote g is intended to

distinguish between 1/2 and 1/4 mask elastomeric face

pieces; the latter not providing an acceptable seal.

Disposable half-mask respirators that provide a good seal

are recent innovations. NRC is currently considering

amending 10 CFR 20 to add a disposable respirator

classification to Appendix A; however, the PF to be

assigned to this class has not been established. Until

Part 20 is amended to add a disposable respirator

classification, NRC licensees wishing to use 3M respirators

can apply to the Commission for authorization under

paragraph 10 CFR 20.103 (d) [or 10 CFR 20.1703 (a) (2)].

Regulatory references: 10 CFR 20.103, 10 CFR 20.1703

Subject codes: 8.10

Applicability: All