Health Physics Questions and Answers - Question 413
Question 413: This question refers to the answers to Questions 66 and 31 under §20.1003 and §20.1201, respectively, and to Question 26 (d) under §20.1003. Simply designating an area as a restricted area so you can control everyone at occupational dose limits is a perversion of every radiation protection principle published. Of course, this is just my opinion. I hope NRC will revise its interpretation of this definition.
For example, a secretary in a nuclear medicine clinic without any direct person-to-person contact with patients should not be subject to occupational limits just because she is in a restricted area. Many other examples could be cited, and some that are more in the gray area should be examined carefully. Clearly, there is a significant population of exposed persons that are not being held to the proper standard. The following statement refers to the answer to Question 26 (d) concerning "individual E." In spite of the definition of occupational dose, mere geography is not justification for classifying a person as a radiation worker.
Answer: The questioner appears to object to the definition of "occupational dose" that states that "occupational dose means the dose received by an individual in a restricted area or . . . ." The NRC cannot change this definition by revising its "interpretation of this definition." The definition can only be changed by rulemaking.
While there may have been a lack of clarity in the referenced answers, our intention is that licensees should not engage in a practice of "simply designating an area as a restricted area so you can control everyone at occupational dose limits." Question 66 asks if a simple fenced area can qualify as a restricted area and the answer is yes, provided it is the licensee's purpose to limit access for the purpose of controlling radiation exposures. Question 31 asks if students and volunteers (such as nuclear medicine students and "candy stripers" who transport nuclear medicine patients or perform volunteer work in a nuclear medicine department) are subject to occupational dose limits. The answer to this question is that these individuals are subject to the occupational dose limits because, and provided that (as the question implies), the type of work they are assigned involves exposure to radiation; it does not matter where (in which area) they are working Question 26 (d) asks if the occupational dose limits or public dose limits apply to "Individual E," a secretary for a radiography company, who works in a "controlled area" next to a "restricted area" containing a hot cell. The answer is that the occupational dose limits apply), again because the type of work assigned presumably involves exposure to radiation since it must be performed near the hot cell.
(References: 10 CFR 20.1003, 10 CFR 20.1201)