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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)