Workplace Controls - doe-hdbk-1184-2004

DOE-HDBK-1184-2004

6 - WORKPLACE CONTROLS

In establishing workplace controls for STCs, the extent of workplace controls should be

commensurate with the hazard presented by the specific STC for which protection is required.

For certain STCs such as certain types of organically bound tritium, existing technology permits

institution of a radiological control system that is commensurate with current systems used to

protect workers from exposure to the oxide and gaseous forms of tritium. Alternatively,

establishing a level of workplace control commensurate with the hazard presented by other

types of STCs (such as ITPs) poses a significant challenge because of difficulties in identifying

and characterizing these types of STCs. As a result of such limitations in individual and

workplace monitoring, the system of workplace controls should be conservative in order to

demonstrate that workers are adequately protected.

6.1 Design/Engineering Controls

Current regulations and standard practices for occupational radiation protection require a

primary reliance on design and engineering controls for protection, unless such controls

are impractical or ineffective. The distinction between design/engineering controls and

administrative controls is not always definitive. For example, an item of protective clothing

that blocks the incident radiation is functioning as a form of shielding, but is most

commonly considered an administrative control. Likewise, a temporary HEPA-filtered

ventilation system may require adherence to administrative procedures to ensure its proper

installation and operation, but is most commonly considered an engineering control. In this

handbook, the term "design/engineering controls" includes such controls as shielding

systems, confinement systems, and ventilation systems. Those controls that require direct

intervention and proper operation by individual users, such as respiratory protection,

protective clothing, and access controls, are considered to be administrative controls.

Because the physical behavior of ITPs mimics that of similar particulates, there are no

design/engineering controls that are unique to ITP contamination in the workplace.

Design/engineering controls for ITPs should be evaluated and applied in the same manner

as for other particulate contaminants, with particular attention to such factors as likelihood

of contamination spread, particle sizes, contamination levels, likely individual doses,

planned and potential activities and events, and planned future uses for the affected area.

Consistent with the as low as reasonably achievable (ALARA) process, consideration

should be given to efforts that may be necessary to recover from the use of engineering

control systems for STC contamination protection, such as special decontamination,

storage and handling needs, purchase of new equipment, and special waste handling

needs.

6.2 Administrative Controls

Following development and implementation of appropriate design features, including

engineering controls, administrative controls are typically developed and applied to ensure

that the design features are properly installed, maintained, and operated. In addition,

administrative controls provide an additional level of safety above and beyond that

provided by the design features alone, consistent with the ALARA process.