United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

Question 91: As long as no credit is taken for the

protection provided by the respiratory protection

equipment, the old Part 20, in 10 CFR 20.103 (c), allows

licensees to use this equipment without meeting the

requirements of 10 CFR 20.103 (c) (1) through 20.103 (c)

(4), inclusive. Has this "loophole" in the old Part 20

been closed in the revised Part 20?

Answer: Yes. 10 CFR 20.1703 (a), which contains

requirements similar to those in 10 CFR 20.103 (c), imposes

these requirements "if a licensee uses respiratory

protection equipment to limit intakes," regardless of

whether the licensee makes "allowance for this use of

respiratory protective equipment in estimating exposures of

individuals . . . ." (Reference: 10 CFR 20.1703)

Page Last Reviewed/Updated Thursday, March 29, 2012