United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

Question 387: In evaluating the use of respirators to

limit intakes, in addition to determining the total

effective dose equivalent (TEDE), should the evaluation and

subsequent decision on whether to use respirators also

consider industrial safety hazards associated with wearing

respirators? For example, added effort increasing the

probability of heat stress, limited range of vision while

climbing, or difficulty of maneuvering readily while

working in confined spaces due to wearing a respirator may

pose potentially greater safety risks than does the

potential dose from uptake of airborne radioactive material

to which an individual might be exposed by not wearing a


Answer: 10 CFR 20.1702 provides for the use of

respirators consistent with maintaining the TEDE as low as

is reasonably achievable. A reduction in the TEDE for a

worker is not reasonably achievable if an attendant

increase in the worker's industrial health and safety risk

would exceed the benefit to be obtained by the reduction in

the radiation risk associated with the reduction in the

TEDE. The NRC has never maintained that application of the

ALARA principle requires ignoring factors other than

radiation that may have an adverse impact on public health

and safety. (References: 10 CFR 20.1702, 10 CFR 20.1703).

Page Last Reviewed/Updated Thursday, March 29, 2012