Guidance Regarding Physicians' Determination of Physical Qualification of Respiratory Equipment Users
See the memorandum from W. L. Fisher to R. E. Hall dated February 1, 1984. This memo states that physicians must make final determinations of fitness for each respiratory equipment user. The health physics position was written in the context of 10 CFR 20.103 (c) (2), but it also applies to "new" 10 CFR 20.1703 (a) (3).
Although physicians need not administer each test personally, it is not acceptable for a physician to establish criteria and have the licensee (or any other designee) use these criteria to make the determination that the individual is or is not qualified. The physician may use a medical designee (such as an office nurse) for signing the medical approval / denial form for the physician, as long as the designee's signature is clearly for administrative convenience and the physician has not relinquished any responsibility for the fitness determination.
Regulatory references: 10 CFR 20.103, 10 CFR 20.1703, Regulatory Guide 8.15, NUREG-0041
Subject codes: 8.10
Page Last Reviewed/Updated Friday, October 13, 2017