[ Index of Health Physics Questions and Answers | NRC Home Page ]
Question 386: In evaluating whether to require the use of
respirators to limit intakes, it is found that wearing a
respirator will likely increase the total effective dose
equivalent (TEDE). However, the workers request that they
be allowed to wear respirators to limit intakes, despite
the results of the evaluation. With regard to NRC
regulation, what discretion may the licensee exercise in
this circumstance?
Answer: 10 CFR 20.1702 provides for the use of
respirators consistent with maintaining the TEDE as low as
is reasonably achievable. Assuming that the licensee has
provided appropriate training to the workers in question,
the licensee may exercise discretion on a case-by-case
basis in determining whether to grant approval to a
worker's request for using a respirator when the TEDE-ALARA
determination dictates that respiratory protection not be
used. The NRC staff realizes that the significant "culture
shift" / "paradigm shift" (i.e., changing from the
traditional operational philosophy of not allowing any
worker intakes to one of allowing some intakes when this is
consistent with the goal of maintaining the TEDE ALARA) may
not take place quickly. Furthermore, acceptance of this
change will certainly be difficult for some individuals.
Therefore, the NRC staff realizes that during this
transition period licensees will need reasonable
flexibility to allow for individual needs and problems in
making this shift. However, the staff expects that over
time the transition to ALARA-TEDE will be made and this
worker acceptance problem will become an exceptional
occurrence. In the meantime, when assigning a respirator
to the requesting worker, the licensee should make every
reasonable effort to provide the worker with a respirator
that minimizes the loss of worker efficiency. Note: The
NRC staff is aware of existing state OSHA regulations that
require an employer to provide a worker with a respirator
upon request; compliance with such state regulations is
acceptable to the NRC staff. See the answer to the
related Question 387. (Reference: 10 CFR 20.1702, 10 CFR
20.1703).