View source for LIC-94-0236, Comment Supporting Proposed Rule 10CFR20 Re Frequency of Medical Exams for Use of Respiratory Protection Equipment. Util Feels Proposed Change Would Be Beneficial in Terms of Cost Savings

{{Adams
| number = ML20077F679
| issue date = 11/11/1994
| title = Comment Supporting Proposed Rule 10CFR20 Re Frequency of Medical Exams for Use of Respiratory Protection Equipment. Util Feels Proposed Change Would Be Beneficial in Terms of Cost Savings
| author name = Gates W
| author affiliation = OMAHA PUBLIC POWER DISTRICT
| addressee name = 
| addressee affiliation = NRC OFFICE OF THE SECRETARY (SECY)
| docket = 05000285
| license number = 
| contact person = 
| case reference number = FRN-59FR47565, FRN-60FR7900, RULE-PR-20
| document report number = 59FR47565-00004, 59FR47565-4, AF08-2-005, AF8-2, AF8-2-5, LIC-94-0236, LIC-94-236, NUDOCS 9412150014
| document type = LEGAL TRANSCRIPTS &amp; ORDERS &amp; PLEADINGS, PUBLIC COMMENTS ON PROPOSED RULES &amp; PETITIONS FOR
| page count = 2
}}

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November 11, 1994 LIC-94-0236 Secretary Docketing and Service Branch U. S. Nuclear Regulatory Commission Washington, DC 20555

==References:==
: 1. Docket No. 50-285
: 2. Federal Register Volume 59, No. 179 (59 FR 47565) dated September 16~, 1994

==SUBJECT:==
Comments on Proposed Rule Regarding Frequency of Medical                      !
Examinations for Use of Respiratory Protection Equipment                      i The NRC proposed changes to 10 CFR Part 20.1703(a)(3)(v) in Reference 2 which              )
would change the annual frequency of medical examinations for use of respiratory           ;
protection equipment. This proposed rule would require determination by a physician prior to initial fitting of respirators, and periodically thereafter, either every 12 months or at a frequency determined by a physician, that the individual user is medically fit to use the respiratory protection equipment.
The NRC noted in Reference 2 that considerable experience with implementation of the current annual examination requirement indicates that the annual frequency of medical examinations is costly and could be reduced significantly with no adverse impact on health and safety.
The Omaha Public Power District (0 PPD) provides the following comments on this proposed rule:
: 1)    The proposed change in frequency of medical examinations would                I l
be beneficial in terms of cost savings.
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                                                                                                                  .t LSectetary, Docketing and Service Branch LIC-94-0236 Page 2                                                                                                  :
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: 2)         Changing the time of the medical examination to "before fi%t field use" instead of "before initial fitting" of respirators, although cost beneficial, may carry legal risks. . For example, if a' fit test' or training was performed prior to the physical examination and the individual experienced a medical problem, the company could be. liable. Many individuals who become
                              " respirator qualified" never wear a respirator after initial                     - ~.
fitting of respirators,-but this practice is necessary to                             ,
provide legal documentation.
: 3)          It should be noted that this change in medical examination-frequency'for NRC licensees can not apply .to all respirator                         a usage. For example, individuals that are qualified asbestos workers can not have their annual medical frequency-changed.                          '
The Occupational Safety and Health Administration (OSHA) Code 1910.1001(I)(3)(i) clearly states these individuals shall have annual medical examinations.       Therefore, it is important that' the individuals selected.for extended medical examinations are not asbestos workers, otherwise an OSHA regulation is violated.
In summary, the cost savings would be beneficial to allow the physician to relax the requirements for routine annual respirator physicals.
If you should have any questions, please contact me.                                                       l
                                                                                                                    )
Sincerely, eu .R h W. G. Gates Vice President WGG/dll c:      LeBoeuf, Lamb, Greene & MacRae L. J. Callan, NRC Regional Administrator, Region IV S. D. Bloom, NRC Project Manager R. P. Mullikin, NRC Senior Resident Inspector Document Control Desk                                                                              !
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