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Protective Actions and Protective Action Guides

Protective Actions

  • Protective actions (protective action recommendations): designed to be taken before an anticipated Protective Action Guide (PAG) dose is reached.
    • Actions taken to reduce or eliminate the public's exposure to radiation or other hazards following an radiation incident
      • In the early and intermediate phases of RDD/IND incidents there may be inadequate information to determine precisely the radiation levels or make dose projections.
      • Initial protective actions may be undertaken based on models rather than actual measured radiation levels.
      • Protective action recommendations may change over the course of an incident, as new information is obtained.
    • Primary protective actions include
      • Sheltering-in-place
      • Evacuation
      • Relocation
      • Interdiction of food and water
    • Secondary protective actions include
      • Medical countermeasure administration
      • Decontamination of people and places
      • Restrictions of food and/or water
      • Access control
      • Victim extraction
    • See also:

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Protective Action Guides (PAGs)

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Exposure Pathways and Protective Actions: Chart

Potential Exposure Pathways and Protective Actions by Incident Phase

Exposure pathways and protective actions

Source: Nuclear/Radiological Incident Annex to the Response and Recovery Federal Interagency Operational Plans, (PDF - 3.38 MB) (US Government Interagency, May 2023, See Figure 5, page 24)

  • Early Phase:
    • The Early Phase is the period at the beginning of the incident when immediate decisions for effective protective actions are required.
    • There may be little or no information available on actual releases or field measurement data.
    • Protective actions in the early phase are aimed at avoiding inhalation of gases or particulates in a plume and minimizing external exposure.
  • Intermediate Phase:
    • The Intermediate Phase may overlap with and/or follow the early phase response within as little as a few hours and can last for weeks or months.
    • This phase is assumed to begin after the incident source and releases have been brought under control and protective action decisions can be made based on measurements of exposure and radioactive materials that have been deposited.
    • Protective actions in the intermediate phase are intended to reduce or avoid dose to the public, control worker exposures and the spread of contamination, and prepare for late-phase cleanup.
  • Late Phase:
    • The Late Phase is the period when actions designed to reduce radiation levels in the environment to acceptable levels are conducted.
    • The late phase entails final clean-up decisions and implementation of remediation strategies.
    • The Late Phase will overlap with the intermediate phase response, making Sub-phase 2c part of both the intermediate and late phases.


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Summary Table for PAGs, Guidelines, and Planning Guidance for Radiological Incidents by Phase of Incident

(Source: EPA PAG Manual 2017 (PDF - 1.48 MB), See Table 1-1, page 6)

Summary Table for PAGs, Guidelines, and Planning Guidance for Radiological Incidentsa

PhaseProtective Action RecommendationPAG, Guideline or Planning Guidance
Early Phase Sheltering-in-place or evacuation of the publicb PAG: 1 to 5 rem (10 mSv to 50 mSv) projected dose over four daysc
Supplementary administration of prophylactic drugs KId PAG: 5 rem (50 mSv) projected child thyroid dosee from exposure to radioactive iodine
Limit emergency worker exposure (total dose incurred over entire response) Guideline: 5 rem (50 mSv)/year (or greater under exceptional circumstances)f
Intermediate Phase Relocation of the public PAG: ≥ 2 rem (20 mSv) projected dosec in the first year, 0.5 rem (5 mSv)/year projected dose in the second and subsequent years
Apply simple dose reduction techniques Guideline: < 2 rem (20 mSv) projected dose c in the first year
Food interdictiong PAG: 0.5 rem (5 mSv)/year projected whole body dose, or 5 rem (50 mSv)/year to any individual organ or tissue, whichever is limiting
Drinking water PAG: 100 mrem (1 mSv or 0.1 rem) projected dose, for one year, to the most sensitive populations (e.g., infants, children, pregnant women and nursing women);
500 mrem (5 mSv or 0.5 rem) projected dose, for one year, to the general population
Limit emergency worker exposure (total dose incurred over entire response) Guideline: 5 rem (50 mSv)/year
Reentry Guideline: Operational Guidelinesh (stay times and concentrations) for specific reentry activities (See Section 4.6)
Late Phase Cleanup i Planning Guidance: Brief description of planning process (see Section 5.1)
Waste Disposal Planning Guidance: Brief description of planning process (see Section 5.2)
a This guidance does not address or impact site cleanups occurring under other statutory authorities such as the United States Environmental Protection Agency’s (EPA) Superfund program, the Nuclear Regulatory Commission’s (NRC) decommissioning program, or other federal or state cleanup programs.

b Should begin at 1 rem (10 mSv); take whichever action (or combination of actions) that results in the lowest exposure for the majority of the population. Sheltering may begin at lower levels if advantageous.

c Projected dose is the sum of the effective dose from external radiation exposure (e.g., groundshine and plume submersion) and the committed effective dose from inhaled radioactive material.

d Provides thyroid protection from radioactive iodines only. See the complete 2001 FDA guidance, "Potassium Iodide as a Thyroid Blocking Agent in Radiation Emergencies." Further information is also available in “KI in Radiation Emergencies, 2001 – Questions and Answers” 2002, and “Frequently Asked Questions on Potassium Iodide (KI).”

e Thyroid dose. See Section 1.4.2. For information on radiological prophylactics and treatment other than KI, refer to https://www.fda.gov/Drugs/EmergencyPreparedness/BioterrorismandDrugPreparedness/ucm063807.htm, https://www.emergency.cdc.gov/radiation, and www.orau.gov/reacts.

f When radiation control options are not available, or, due to the magnitude of the incident, are not sufficient, doses to emergency workers above 5 rem (50 mSv) may be unavoidable and are generally approved by competent authority. For further discussion see Chapter 3, Section 3.1.2. Each emergency worker should be fully informed of the risks of exposure they may experience and trained, to the extent feasible, on actions to be taken. Each emergency worker should make an informed decision as to how much radiation risk they are willing to accept to save lives.

g For more information on food and animal feeds guidance, the complete FDA guidance may be found at https://www.fda.gov/downloads/MedicalDevices/DeviceRegulationandGuidance/GuidanceDocuments/UCM094513.pdf.

h For extensive technical and practical implementation information please see "Preliminary Report on Operational Guidelines Developed for Use in Emergency Preparedness and Response to a Radiological Dispersal Device Incident" (DOE 2009).

i This cleanup process does not rely on and does not affect any authority, including the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), 42 U.S.C. 9601 et seq. and the National Contingency Plan (NCP), 40 CFR Part 300. This document expresses no view as to the availability of legal authority to implement this process in any particular situation.

(Source: EPA PAG Manual 2017 (PDF - 1.48 MB), See Table 1-1, page 6)

  • See more detailed guidance in the EPA PAG Manual for
    • PAGs and Protective Actions for the Early Phase of Radiological Incident (page 16)
    • PAGs and Protective Actions for the Intermediate Phase of Radiological Incident (page 42)
    • Reentry matrix: Quick Reference to Operational Guidelines (page 50) and below on this page.
  • See REMM page on Phases of a radiation incident

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PAGs and Protective Actions for the Early Phase of a Radiological Incident

PAGS and Protective Actions for the Early Phase of a Radiological Incidenta

Protective Action Recommendation PAG Comments
Sheltering-in-place or evacuation of the publicb PAG: 1 to 5 rem (10 mSv to 50 mSv) projected dose over four daysc Evacuation (or, for some situations, sheltering-in-place) should be initiated when projected dose is 1 rem (10 mSv).
Supplementary administration of prophylactic drugs - KId PAG: 5 rem (50 mSv) projected child thyroid dosee from exposure to radioactive iodine KI is most effective if taken prior to exposure. May require approval of state medical officials (or in accordance with established emergency plans).
a This guidance does not address or impact site cleanups occurring under other statutory authorities such as the United States Environmental Protection Agency’s (EPA) Superfund program, the Nuclear Regulatory Commission’s (NRC) decommissioning program, or other federal or state cleanup programs.

b Should begin at 1 rem (10 mSv) if advantageous except when practical or safety considerations warrant using 5 rem (50 mSv); take whichever action (or combination of actions) that results in the lowest exposure for the majority of the population. Sheltering may begin at lower levels if advantageous.

c Projected dose is the sum of the effective dose from external radiation exposure (e.g., groundshine and plume submersion) and the committed effective dose from inhaled radioactive material.

d Provides thyroid protection from radioactive iodines only. The complete FDA guidance may be found at https://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/ucm080542.pdf. Further information is also available: https://www.fda.gov/downloads/Drugs/GuidanceComplianceRegulatoryInformation/Guidances/ucm080546.pdf and https://www.fda.gov/Drugs/EmergencyPreparedness/BioterrorismandDrugPreparedness/ucm072265.htm.

e Thyroid dose. For information on radiological prophylactics and treatment other than KI, refer to https://www.fda.gov/Drugs/EmergencyPreparedness/BioterrorismandDrugPreparedness/ucm063807.htm, https://www.emergency.cdc.gov/radiation, and www.orau.gov/reacts. The one-year old age group is expected to receive the largest dose to the thyroid from exposure to radioactive iodine. Therefore, it is recommended that the one-year old age group is considered when considering the administration of prophylactic KI.

(Source: EPA PAG Manual 2017 (PDF - 1.48 MB), See Table 2-1, page 16)

  • See PAG Manual for detailed guidance about the Early Phase of an Incident


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EPA Emergency Worker Exposure Guidelines

(Source: EPA PAG Manual 2017 (PDF - 1.48 MB), See Table 3-1, page 35)

(Bullets below are from the Manual)

  • Emergency worker guidelines are based on cumulative dose constraint levels incurred over the duration of an emergency and are assumed to be “once in a lifetime” doses and that future radiological exposures would be substantially lower
  • Recommendations in this Manual provide a guideline level of 5 rem (50 mSv) for worker protection and alternative emergency worker guidelines (see Table 3-1) for certain activities where doses above 5 rem (50 mSv) cannot be avoided.
  • For most radiological incidents, radiation control measures (e.g., minimizing time, maximizing distance, using shielding) will prevent doses from reaching the 5 rem (50 mSv) occupational exposure guideline while performing typical emergency response activities such as transportation, firefighting and medical treatment of contaminated victims at hospitals.
  • However, in those situations in which victims are injured or trapped in high radiation areas or can only be reached via high radiation areas, or for protection of critical infrastructure, exposure control options may be unavailable or insufficient and doses above 5 rem (50 mSv) may be unavoidable.
  • Decisions to take response actions that could result in doses in excess of 5 rem (50 mSv) can only be made at the time of the incident, under consideration of the actual situation.
    • In such situations, incident commanders and other responders need to understand the risk posed by such exposures in order to make informed decisions.
  • The emergency worker guidelines for life and property saving activities in Table 3-1 are provided to assist such decision-making.
    • These guidelines apply to doses incurred over the duration of an emergency and are assumed to be once in a lifetime.
    • After the early phase, it is likely that no more lifesaving missions would be needed.
    • However, some critical infrastructure/key resources or lifesaving missions may arise in the intermediate phase, where these guidelines would apply.
  • Emergency personnel may be exposed to increased radiation during the unique catastrophic event of an IND detonation resulting in firestorm and widespread destruction of structures.
  • The emergency intervention needed to prevent further destruction and loss of life may result in increased exposure.
  • Exceeding the emergency worker guidelines in Table 3-1 may be unavoidable in responding to such events.
  • For all exposures, emergency workers must be fully informed of the risks of exposure they may experience, including numerical estimates of the risk of delayed health effects, and must be trained, to the extent feasible, on actions to be taken.
  • Each emergency worker should make an informed decision as to how much radiation risk they are willing to accept to complete a particular mission.
  • The 25 rem (250 mSv) lifesaving emergency worker guidelines provide assurance that exposures will not result in detrimental deterministic health effects (i.e., prompt or acute effects).
    • However, it could increase the risk of stochastic (chronic) effects, such as the risk of cancer.
  • Response actions that could cause exposures in excess of the 25 rem (250 mSv) emergency worker guideline should only be undertaken with an understanding of the potential acute effects of radiation to the exposed responder (see Table 3-2) and only when the benefits of the action (i.e., lifesaving or critical infrastructure/key resource protection) clearly exceed the associated risks.
  • See PAG document for important additional details.

Guideline

Worker Activity

Condition

5 rem (50 mSv)

All occupational exposures
  • All reasonably achievable actions have been taken to minimize dose.

10 rem (100 mSv)a

Protecting critical infrastructure necessary for public welfare (e.g., a power plant)
  • Exceeding 5 rem (50 mSv) is unavoidable and all appropriate actions and controls have been implemented.
  • Monitoring available to project or measure dose.

25 rem (250 mSv)b

Lifesaving or protection of large populations
  • Exceeding 5 rem (50 mSv) is unavoidable, and all appropriate actions and controls have been implemented.
  • Monitoring available to project or measure dose.

>25 rem (250 mSv)

Lifesaving or protection of large populations
  • All conditions above and only for people fully aware of the risks involved (see Tables 3-2 and 3-3)

a For potential doses >5 rem (50 mSv), medical monitoring programs should be considered.

b In the case of a very large incident, such as an IND, incident commanders may need to consider raising the property and lifesaving emergency worker guidelines to prevent further loss of life and massive spread of destruction.

NCRP recommends, when the cumulative absorbed dose to an emergency responder reaches 50 rad (0.5 Gy), a decision be made on whether or not to withdraw the emergency responder from the Hot Zone (>10 mR/h = >0.1 mSv/h.  NCRP considers the 50 rad (0.5 Gy) cumulative absorbed dose a decision dose, not a dose limit. (Source: Responding to a radiological or nuclear terrorism incident: a guide for decision makers. Bethesda, MD: NCRP. Report No. 165, 2011)

This guidance does not address or impact site cleanups occurring under other statutory authorities such as the United States Environmental Protection Agency’s (EPA) Superfund program, the Nuclear Regulatory Commission’s (NRC) decommissioning program, or other federal or state cleanup programs.

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Protective Action Guidance for Food and Drinking Water

  • The EPA PAG Manual 2017, (Section 4.6, pages 53-68), contain extensive guidance on this topic.
  • See REMM page for more details on Monitoring Radionuclides in Drinking Water and Food: Routinely and After a Release
  • The bullets below are quoted from the EPA PAG Manual 2017 document
    • EPA developed a new drinking water PAG as non-regulatory guidance to protect the public in the event of a radiological incident that affects drinking water supplies.
    • The purpose of the protective action for the drinking water exposure pathway is to restrict the use of contaminated water for drinking and to provide recommendations for local communities to consider in providing alternative drinking water for the affected community during a nationally significant radiological incident, such as a disaster at a nuclear power plant, an RDD or an IND.
    • The drinking water PAGs apply during the intermediate phase of an incident, which may last for weeks to months but not longer than one year.
    • This guidance only provides recommendations and does not confer any legal rights or impose any legally binding requirements upon any member of the public, states, or any other federal agency.
    • The drinking water PAG will help federal, state, local and public water system officials make decisions about use of water during radiological emergencies.
    • The drinking water PAG is for use only during an emergency; it is not a substitute for compliance with EPA’s National Primary Drinking Water Regulations (NPDWRs) for Radionuclides. EPA expects that any drinking water system adversely impacted during a radiation incident will take action to return to compliance as soon as possible
  • The PAG includes both EPA guidance and other standards as wells as guidance about how to interpret and apply the PAG guidance
  • Drinking water guidance in the PAG manual discusses the following
    • Safe Drinking Water Act (SDWA) (EPA)
    • Derived Response Levels (DRLs) for radionuclides likely to appear in drinking water following a radiological contamination incident.
    • Maximum contaminant level (MCL) for radionuclides in water
  • Information from Public Health England about Drinking Water Supplies (PHE, 2015)
  • Information from Public Health England about Food Production Systems (PHE, 2015)

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Generalized Protective Action Areas for Nuclear Power Plant Incident

(Source: EPA PAG Manual 2017 (PDF - 1.48 MB), See Figure 4-1, page 54. See also entire PAG Manual section on Intermediate Phase: Relocation and Dose Reduction)

Generalized protective action areas for nuclear power plant incident

(Source: EPA PAG Manual 2017 (PDF - 1.48 MB), See Figure 4-1, page 54. See also entire PAG Manual section on Intermediate Phase: Relocation and Dose Reduction)

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Protective Action Guides for Exposure to Deposited Radioactivity during the "Intermediate Phase" of a Radiological Incident

(Source: EPA PAG Manual 2017 (PDF - 1.48 MB), See Table 4-1, page 42)

PAGs and Protective Actions for Exposure to Deposited Radioactivity during the Intermediate Phase of a Radiological Incidenta

Protective Action Recommendation PAG or Guideline Comments
Relocation of the publicb PAG: ≥ 2 rem (20 mSv) projected dosec in the first year,
0.5 rem (5 mSv)/year projected dosec in the second and subsequent years 		Projected dose over one year of exposure.
Apply simple dose reduction techniquesd Guideline: < 2 rem (20 mSv) projected dosec in the first year These protective actions should be taken to reduce doses to as low as practicable levels
Food interdictione PAG: 0.5 rem (5 mSv)/year projected whole body dose, or 5 rem (50 mSv)/year to any individual organ or tissue, whichever is limiting  
Drinking Water PAG: 100 mrem (1 mSv or 0.1 rem) projected dose, for one year, to the most sensitive populations (e.g., infants, children, pregnant women and nursing women);
500 mrem (5 mSv or 0.5 rem) projected dose, for one year, to the general population 		See Section 4.6
Reentry Guideline: Operational Guidelinesf (stay times and concentrations) for specific reentry activities (see Section 4.6)  
a This guidance does not address or impact site cleanups occurring under other statutory authorities such as the United States Environmental Protection Agency’s (EPA) Superfund program, the Nuclear Regulatory Commission’s (NRC) decommissioning program, or other federal or state cleanup programs.

b People previously evacuated from areas outside the relocation area defined by this PAG may return to occupy their residences. Cases involving relocation of people at high risk from such action (e.g., patients under intensive care) may be evaluated individually.

c Projected dose refers to the dose that would be received, by default, in the absence of shielding from structures or the application of dose reduction techniques. These PAGs may not provide adequate protection from some long-lived radionuclides (see Section 4.5). Incident-specific factors should be considered.

d Simple dose reduction techniques include scrubbing or flushing hard surfaces, minor removal of soil from spots where radioactive materials have concentrated, and spending more time than usual indoors or in other low exposure rate areas.

e For more information on food and animal feeds guidance, the complete FDA guidance may be found at https://www.fda.gov/downloads/MedicalDevices/DeviceRegulationandGuidance/GuidanceDocuments/UCM094513.pdf.

f For extensive technical and practical implementation information please see "Preliminary Report on Operational Guidelines Developed for Use in Emergency Preparedness and Response to a Radiological Dispersal Device Incident" (DOE 2009).


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Reentry Matrix Following a Radiation Incident or Accident by Phase of Incident

(Source: EPA PAG Manual 2017 (PDF - 1.48 MB), See Table 4-2, page 50-52)

Reentry matrix following a radiological incident or accident

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Worker Protection Recommendations from Professional Societies

Agency

Summary Information

Original Document

National Council on Radiation Protection and Measurements (NCRP)

Recommendations for Emergency Responders

Responding to a Radiological or Nuclear Terrorism Incident: A Guide for Decision Makers (PDF - 1.61 MB) (NCRP Report No. 165, Section 3.2.1 and 3.2.2), Bethesda, MD, 2010.

National Council on Radiation Protection and Measurements (NCRP)

NCRP Radiation Protection Guidelines: Control of Radiation Dose in the Control Zones

Key Elements of Preparing Emergency Responders for Nuclear and Radiological Terrorism (NCRP Commentary No. 19), National Council on Radiation Protection and Measurements, Bethesda, MD, December 2005, page 19. Purchase required.

International Atomic Energy Agency (IAEA)

IAEA Emergency Worker Turn-back Dose Guidance

Manual for First Responders to a Radiological Emergency (PDF - 2.2 MB) (CTIF, IAEA, PAHO, WHO, October 2006, page 41)

International Atomic Energy Agency (IAEA)

Updated guidance based on exercises and actual incidents with comprehensive safety standards for protecting people and the environment.

Preparedness and Response for a Nuclear or Radiological Emergency, IAEA Safety Standards Series GSR part 7, 2015 (Jointly sponsored by IAEA and 12 other organizations noted on cover page)

Conference of Radiation Control Program Directors, Inc. (CRCPD)

CRCPD Turn-back Exposure Rates and Dose Guidelines

Handbook for Responding to a Radiological Dispersal Device (Dirty Bomb): First Responder's Guide: The First 12 Hours (CRCPD Publication 06-6) (page 28) Conference of Radiation Control Program Directors, Inc. Frankfort, Kentucky, 2006.

International Commission on Radiological Protection (ICRP)

ICRP Guidance for Occupational Exposure

Protecting People Against Radiation Exposure in the Event of a Radiological Attack (ICRP Publication 96), International Commission on Radiological Protection, 2005, page 51.


See also: Personal Protective Equipment (PPE)

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Reference Values for Emergency Responder Radiation Safety

Terminology

Accumulated Dose

Recommended Application or Action

Document

Response worker guidelines

5 rem
(50 mSv)

10 rem
(100 mSv)

≥25 rem
(≥250 mSv)

All occupational exposures


Protect critical infrastructure


Lifesaving or protection of large populations

PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incidents (EPA, 2017)

Decision dose

50 rad
(0.5 Gy)

Decide whether to remove responder or continue mission, based on operational awareness and mission priorities

NCRP Report No. 165, Responding to a Radiological or Nuclear Terrorism Incident: A Guide for Decision Makers (NCRP, 2010)

Turn-back dose guidance

50 rem
(500 mSv)

100 rem (1 Sv)

Prevent severe health effects or injuries


Lifesaving actions

Manual for First Responders to a Radiological Emergency (IAEA, 2006)

Cold zone
("outer perimeter")

≤0.01 R h-1
(~0.1 mGy h-1)

Alarm threshold

Key Elements of Preparing Emergency Responders for Nuclear or Radiological Terrorism (NCRP, 2005)

Hot zone

>0.01 R h-1
(~0.1 mGy)

Routine response activities performed with personal protective equipment, including active radiation monitoring

Key Elements of Preparing Emergency Responders for Nuclear or Radiological Terrorism (NCRP, 2005)

Dangerous-radiation zone

≥10 R h-1
(~0.1 Gy h-1)

Restrict actions to time sensitive, mission critical such as lifesaving

NCRP Report No. 165, Responding to a Radiological or Nuclear Terrorism Incident: A Guide for Decision Makers (NCRP, 2010)

Turn back

200 R h-1
(~2 Gy h-1)

Responders should turn back, even when working on life saving missions

Handbook for Responding to a Radiological Dispersal Device: First Responders Guide — The First 12 Hours (CRCPD, 2006)

Note: Local agencies may have alternate guideline values for responder operations.

Source: Guidance for Emergency Response Dosimetry (NCRP Report 179), National Council on Radiation Protection and Measurements, Bethesda, MD, 2017, Table 4.1.



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Regulations for Worker Protection: US Government Agencies

  • The Occupational Safety and Health Act requires employers to be responsible for the health and safety of their employees during routine and emergency operations. OSHA guidance may not be fully applicable in a large emergency when workers who are not trained as "radiation workers" are added to the response force.
  • This is a very complex topic.
  • The EPA PAG Manual 2017 (PDF - 1.48 MB), in Table 3-3, page 38, shown below, provides more detailed guidance than is provided on REMM.

Regulations for Worker Protection

Agency Statutory Requirement Title
Occupational Safety and Health Administrationa 29 CFR 1910.120 Safety and Health-- HAZWOPER
29 CFR 1910.1096 Ionizing Radiation
Environmental Protection Agencya 40 CFR 311 Occupational Radiation Protection
Nuclear Regulatory Commissionb 10 CFR 20 Standards for Protection Against Radiation
Department of Energyc 10 CFR 835 Radiation Protection Regulations
a Worker safety and health is regulated in all states by federal OSHA or by respective state regulations under an OSHA-approved state plan. 40 CFR Part 311 applies the OSHA HAZWOPER standard (29 CFR 1910.120) to public-sector workers in states that do not operate their own occupational safety and health programs.

b It is the NRC’s position (56 FR 23365) that dose limits for normal operations should remain the primary guideline in emergencies to the extent practicable. However, in accordance with 10 CFR 20.1001(b), conformance with such dose limits should not hinder an NRC licensee from taking actions that may be necessary to protect public health and safety in an emergency.

c These requirements apply to all DOE employees and contractors (except for Naval Nuclear Propulsion Program (NNPP)) who may be exposed to ionizing radiation as a result of their work for DOE, including work relating to emergency response activities. The NNPP has established requirements consistent with those contained in 10 CFR Part 835.