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# Guidance Concerning 10 CFR 20.103 and Use of Pressure Demand SCBA's

## HPPOS-094 PDR-9111210195

See the memorandum from L. J. Cunningham to L. R. Greger dated September 8, 1983.

Personnel having any condition, including facial hair, that prevents a leak-tight seal and proper operation, should not be qualified respirator wearers. For emergency entries, a licensee can use post-work whole body counts to show compliance with 10 CFR Part 20 intake limits.

The health physics position was written in the context of 10 CFR 20.103, but it also applies to "new" 10 CFR 20.1703. HPPOS-116 contains a related topic. Guidance was requested concerning 10 CFR 20.103 [or 10 CFR 20.1703] and the use of pressure demand SCBA's.

A Region III licensee's proposed respiratory protection plan to allow bearded personnel to use pressure demand SCBA's was discussed with RES and NIOSH. Region III objected to the licensee's proposal but could find no clear regulatory basis for the objection. IE supported the objection and felt there was a strong technical basis for that objection.

IE found several technical flaws in the licensee's proposal to deviate from the normal industry practice of requiring clean-shaven faces in the seal area of tight fitting respirators. One serious problem is the potential to "overbreathe" (e.g., a person working under heavy physical stress, such as fire fighting efforts, can exceed the SCBA's air supply capacity). When a beard-caused leak exists in the seal area, the additional "makeup" air is drawn from the outside atmosphere through the leak area.

Another problem is the beards interference with the operation of the facepiece's exhaust (exhalation) valve. A beard can hold this valve open, and on a deep breath, could allow outside, contaminated air to enter the facepiece. Also, on a normal volume inhalation an open exhaust valve could allow loss of air, thereby reducing the user's service time.

A major problem with the licensee's proposal centers on the high probability for increased outward leakage caused by beard interference with the seal. The Industrial Hygiene Support Group at Lawrence Livermore National Laboratory (LLNL) has noted during testing of bearded personnel that the SCBA advertised 30-minute air supply (which normally lasts about 20 minutes) ran out in 10 to 12 minutes at a moderate work load.

As reported in an article, "Facial Hair and Breathing Protection" (The International Fire Chief, December 1980): "It must be emphasized again that facial hair characteristics change daily, so any test of facepiece fit or how long the breathing air cylinder will last on one day will be different on succeeding days."

IE and NIOSH believe that a daily quantitative fit test would probably be required to ensure adequate air supply service time for bearded users who have facial hair in the seal area. The administrative costs and problems with such a program seem to be tremendous.

IE also addressed a specific question on whether 10 CFR 20.103 (a) (3) [or 10 CFR 20.1204 (a)] permits the use of post-exposure whole body counts to determine compliance with Part 20 intakes. The regulations allow licensees who choose not to fully implement the respiratory protection program of 10 CFR 20.103 (c) (2) [or 10 CFR 20.1703 (a) (3)] to use respirators, but does not allow them to take any credit for protection factors [see 10 CFR 20.1204 (b)].

IE feels this is a reasonable position from the perspective of providing workers protection during routine, planned operations in airborne radioactivity areas. For these operations, the degree of hazard can be pre-determined by air sampling, and licensees can then assume no protection factors and limit the stay time such that administrative intake "overexposures" should not occur. However, the case for fire fighters differs drastically. Prompt emergency response does not lend itself to pre-work assessment of airborne hazards. In emergency situations, it is clearly illogical to take a "no-protection" assumption for entry into IDLH areas of unknown hazards.

In the case of fire fighters, exposure to radioactive materials is generally of secondary importance, and toxic fumes / gases are the principal hazard. However, a strict legal reading of the regulations leads us to conclude that nothing prohibits using post-work whole body counts for demonstrating compliance with Part 20 limits. From a routine radiological perspective, IE is comfortable with this reading; however, in the case of unqualified respirator wearers performing emergency response actions in high risk areas with the attendant unknown level of protection, IE strongly believes the regulations should require high quality respiratory protection.

**Regulatory references:** 10 CFR 20.103, 10 CFR 20.1204, 10 CFR 20.1703

**Subject codes:** 8.2, 8.4, 8.10

**Applicability:** All

Page Last Reviewed/Updated Friday, October 13, 2017