ML20217L814
| ML20217L814 | |
| Person / Time | |
|---|---|
| Issue date: | 04/02/1998 |
| From: | Paperiello C NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Bird P NRC OFFICE OF PERSONNEL (OP) |
| References | |
| NUDOCS 9804070390 | |
| Download: ML20217L814 (2) | |
Text
D April 2, 1998
, ~.
MEMORANDUM TO: Paul E. Bird, Director Office of Human Resources FROM: Carl J. Paperiello, Director [ William F. Kane for:]
Office of Nuclear Material Safety and Safeguards 4
SUBJECT:
NMSS REVIEW OF REVISION TO MANAGEMENT DIRECTIVE 10.130 We have reviewed the proposed changes to Management Directive 10.130, NRC Safety and Health Program Under the Occupational Safety and Health Act, and we concur. The following comments are provided for your use:
- 1. The change to 10.130-035(d)(i) states that a written, NRC respiratory protection program is not required when employees use a licensee respiratory protection program. However, the second sentence of the note states that this exemption doesn't apply to non-radiological tasks. We believe the second sentence is unnecessary and should be deleted. The provisions in 29 CFR 1926.103 require respiratory protection programs for all types of hazards and use of these programs in lieu of an NRC program should be permitted even when the hazard is non-radiological. -
- 2. We note that the requirements for respiratory protection and other occupational safety requirements are only directed at Regional Administrators. There are inspectors that operate out of Headquarters offices and we believe these safety requirements should apply to those offices as well.
CONTACT: Kevin M. Ramsey, NMSS/IMNS (301) 415-7887 DISTRIBUTION: NMSS 9800100 g NRC File Center NMSS r/f IMNS r/f CPoland ) ,
RBrown PTing GSmith RJohnson NMSS Dir. Off. c4 g DOCUMENT NAME: P:\BIRDMEM1.WPD *See previous concurrence op/enoormo/arnn. i, sese Ts recetve a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with att$chment/ enclosure "N" = No copy OFFICE OB* lC OB* l lMNS* l N$@g lg l l NAME KRamsey FCombs DCool CM4hIsilo I '
DATE 3/30/98 4/1/98 4/1/98 4/1/98 OFFICIAL RECORD COPY NHC FILF CENTER CDPQ g yes"c um 9904070390 980402 PDR ORG NOMA
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MEMORANDUM TO: Paul E. Bird. Director Office of Human Resources i
FROM: Carl J. Paperiello, Director Office of Nuclear Material Safety {
and Safeguards l
SUBJECT:
NMSS REVIEW OF REVISION TO MANAGEMENT DIRECTIVE
)
i 10.130 f
I1 We have reviewed the proposed changes to Management Directive 10.130, NRC Safety and Health Program Under the Occupational Safety and Health Act, and we concur. The following comments are provided for your use:
)
\
- 1. The change to 10.130-035(d)(i) states that a written, NRC respiratory protection program is not required when employees use a licensee respiratory protection program. However, the second sentence of the note states that this exemption .
doesn't apply to non-radiological tasks. We believe the second sentence is unnecessary and should be deleted. The provisions in 29 CFR 1926.103 require !
respiratory protection programs for all types of hazards and use of these l programs in lieu of an NRC program should be permitted even when the hazard j is non-radiological. j i
- 2. We note that the requirements for respiratory protection and other occupational safety requirements are only directed at Regional Administrators. There are inspectors that operate out of Headquarters offices and we believe these safety requirements d.vuld apply to those offices as well.
CONTACT: Kevin M. Ramsey, NMSS/IMNS (301)415-7887 DISTRIBUTION: NMSS Ticket 9800100 (3/30/98)
NRC File Center NMSS r/f IMNS r/f CPoland RBrown PTing GSmith RJohnson W $ VeS .__ o DOCUMENT NAME: b/9h 3 3 l((Cfs'E' = Copy with attachment / enclosure Ta receive a copy of this document, indcate in the box: "C" f='Kopy without attache tent / enclosure *W = No copy OFFICE OB C ODxd M l IMNS, p l NMSS l NAME KRamsey fmtf F(pribs j D d56f V CPaperiello DATE 3/30/98 (/lC *
$ / /98 3/ /98 OFFICIAL RECORD COPY