Health Physics Questions and Answers - Question 387
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 respirator.
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)