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Question 101: 10 CFR 20.1202 (d) requires licensees to
evaluate and, to the extent practical, account for intakes
through wounds or skin absorption. What type of
"evaluation" is appropriate for determining absorption
through the skin from skin contamination, and at what
"practical level" should it be accounted for? For what
nuclides, using what criteria can absorption be neglected
under a certain threshold, such as less than 10K, 100K of
skin contamination?
Answer: The requirement to evaluate and account for
intakes through wounds or skin absorption is not new. The
old Part 20 has similar requirements [10 CFR 20.103 (a)
(1)]. Therefore, the "type of evaluation" that has been
used before, if adequate, can continue to be used. The
statement in the old Part 20 (10 CFR 20.103, Footnote 4)
that such intakes should "be evaluated and accounted for by
techniques and procedures as may be appropriate to the
circumstances" continues to be appropriate guidance for the
revised Part 20. Reference: 10 CFR 20.1202 (d)).