Health Physics Questions and Answers - Question 101
Question 101: 10 CFR 20.1202 (d) requires licensees to evaluate and, to the extent practical, account for intakes through wounds or skin absorption. What type of "evaluation" is appropriate for determining absorption through the skin from skin contamination, and at what "practical level" should it be accounted for? For what nuclides, using what criteria can absorption be neglected under a certain threshold, such as less than 10K, 100K of skin contamination?
Answer: The requirement to evaluate and account for intakes through wounds or skin absorption is not new. The old Part 20 has similar requirements [10 CFR 20.103 (a) (1)]. Therefore, the "type of evaluation" that has been used before, if adequate, can continue to be used. The statement in the old Part 20 (10 CFR 20.103, Footnote 4) that such intakes should "be evaluated and accounted for by techniques and procedures as may be appropriate to the circumstances" continues to be appropriate guidance for the revised Part 20.
( Reference: 10 CFR 20.1202 (d)).