United States Nuclear Regulatory Commission - Protecting People and the Environment

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

HPPOS-225 PDR-9111220136

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 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

Page Last Reviewed/Updated Tuesday, June 30, 2015