10 CFR Part 20, subparts B, C, D, F and G

 Subpart B – Radiation Protection Programs (Kristen Dezell):

o Subpart B requires that a radiation protection program be implemented to ensure
compliance of radiation protection principles and required recordkeeping according to
section 20.2102. The licensee should use procedures and controls based on quality
radiation protection principles to achieve occupational and public dose limits as low
as reasonably achievable (ALARA), and the licensee must annually (at minimum)
review the radiation protection program content and implementation. Furthermore,
ALARA requirements include a limit on air emissions of radioactive material to the
environment (excluding Radon-222 and its daughters) so that an individual member
of the public that could receive the highest dose would not be expected to receive a
total effective dose equivalent above 10 mrem (0.1 mSv) per year. If this dose
constraint is exceeded, the licensee must report the exceedance according to section
20.2203 and immediately take corrective action to ensure it will not happen again.1
This is especially applicable to brachytherapy while working with radioisotopes
emitting alpha particles, beta particles, and gamma rays into the environment.

1. 10 CFR Part 20 Subpart B. Code of Federal Regulations. Updated May 20, 2022.
Accessed May 30, 2022.
https://www.ecfr.gov/current/title-10/chapter-I/part-20/subpart-B/section-20.1101

 Subpart C – Occupational Dose Limits (Lauren Jankowski, Paige Solie, & Courtney
Williams):
o The Code of Federal Regulations (CFR) Title 10, subpart C, describes the
occupational dose limits for both adults and minors and further describes internal
versus external exposures. The annual limit for the total effective dose equivalent is
equal to 5 rems (.05 Sv), or the sum of the deep-dose equivalent and the committed
dose equivalent to any individual organ or tissue equal to .5 Sv for adults. For minors,
the annual occupational dose limits are one tenth of these values. It outlines that as a
licensee, you are responsible for minimizing and controlling dose limits to all adults
and minors except for those that are planned for. And, if there is an accidental
exposure, it must be taken into account and subtracted from any planned exposure if
possible.

For an embryo, limits should not exceed 0.5 rem (5 mSv) for the duration of the
declared pregnancy. Section 20.1208 also specifies that the licensee must make an
effort to avoid any additional radiation above the typical monthly exposure rate to any
declared pregnant woman. If the dose equivalent to the fetus is found to be above 0.5
rem, or is within 0.05 rem of this amount, the licensee can remain in compliance if
the additional dose to the fetus does not exceed 0.05 rem for the rest of the pregnancy.
It has been observed at our respective clinical sites that upon a radiation therapist
disclosing that they are pregnant they are given a second dosimeter badge to wear on
a lanyard hanging at their abdominal level. This is an example of how workers are
protected by the CFR and entitled to safety in the workplace.

Subpart C subcategorizes dose equivalents into 3 parts: deep-dose equivalent,

shallow-dose equivalent, and lens dose equivalent. Shallow-dose equivalent is the
dose averaged over the contiguous 10 cm2 of skin receiving the highest exposure.
Deep-dose equivalent is used when external exposure is measured with an external
monitoring device and must be for the part of the body receiving the highest dose.
The annual dose limit to the lens is 15 rems (0.15 Sv). All 3 of these parameters must
be considered when determining the dose from airborne radioactive material in
external exposure.

Licensees may authorize adult radiation workers to receive additional dose for
planned special exposures. The dose must be accounted for separately, can be used
for evaluations, and cannot be used to limit future occupational dose. Planned
exposures must only occur when no other option is available. The employee must
understand the risk factors prior to, and an estimated exposure must be calculated and
subtracted from the employee’s annual and lifetime limit to ensure they will not
exceed these limits prior to the planned exposure. The licensee must also record and
inform the employee of the best estimate of the resulting dose from said planned
exposure. The licensee and employer, if the employer is not also the licensee, must
authorize the additional dose exposure, in writing, prior to the exposure. Within 30
days of the planned exposure, the licensee must submit and maintain a written report
of the planned special exposure conduct and each individual’s best-estimated received
dose.

In addition to keeping track of planned exposures and accidental exposures, the

licensee must determine the potential for and calculate internal and external
exposures. One way a licensee may accomplish this is by measuring the concentration
of radioactive materials in the air within work areas and assessing the quantities of
radionuclides in the body or excreted from the body. Subpart 20.1204 points C-H
outline more specifically on how to account for these measurements. They state that
known physical and chemical properties of radionuclides on the body can be used to
calculate effective dose equivalent as long as the licensee provides documentation in
an individual’s record. Prior approval by the Commission allows for adjustments in
DAC or ALI values to reflect actual physical and chemical characteristics of airborne
radioactive material. Known physical and chemical properties also allow for the
separate contribution assessment of Class D, W, and Y compounds in a radionuclide.
Known radioactive mixtures must be calculated using the sum of the ratio of
concentration to the appropriate DAC value or the ratio of all radionuclides present in
a mixture to the most restrictive DAC value. Intake of Class Y material allows
licensees to delay reports up to seven months for additional measurements. If each
component is known, but concentrations are not known the DAC for the mixture must
be the most restrictive of any present radionuclide. Certain radionuclides may be
disregarding in airborne mixtures when the mixture’s total activity is within dose
limits, monitoring requirements are upheld, the radionuclides are under ten percent of
the DAC concentration, and the sum of the percentages for all disregarded
radionuclides do not exceed thirty percent. For calculations, it can be assumed that
one ALI results in a committed effective dose of 5 rem (0.05 sV). Stochastic ALIs
 can be used to determine effective dose equivalent as long as the licensee can
demonstrate that dose limits from § 20.1201(a)(1)(ii) are met.

1. 10 CFR Part 20 Subpart C. Code of Federal Regulations. Updated April 25, 1995.
Accessed May 31, 2022
https://www.ecfr.gov/current/title-10/chapter-I/part-20/subpart-C/section-20.1101

 Subpart D – Radiation Dose Limits for Individual Members of the Public (Cortney
Cashner):
o Subpart D goes into depth regarding public dose limits. These limits do not take into
account an individual’s exposure from background radiation, radiation from medical
imaging, volunteer medical research radiation, or disposal of radioactive material.
Subpart D only considers dose from being in public unrestricted areas, controlled
areas, and to visitors of held patients. If an operation should result in greater than the
annual dose limit for a member of the public, an authorization application to the NRC
is required. The application must detail the necessity of the operation, its duration, the
program used to control dose, and procedures following the operation that will adhere
to ALARA.
 The total effective dose equivalent to an individual of the public should not
exceed 1mSv/year.
 The total dose limit for an individual of the public should not exceed 5
mSv/year.
 The total dose limit to an unrestricted area should not exceed 0.02mSv/year.
Licensees must also adhere to the standards in 40 CFR part 190, which includes
environmental radiation protection standards, if applicable. The licensees must also
demonstrate surveys of controlled and unrestricted areas in compliance with dose
limits to the public.
A visitor of a held patient should not receive more than 1mSv but if they will receive
greater than 1 mSv then the licensee must ensure the visitor's dose does not exceed 5
mSv if the visit is determined appropriate by an authorized party.1
 1. 10 CFR Part 20 Subpart D. Code of Federal Regulations. Updated October 9, 2002.
Accessed May 25, 2022.
https://www.ecfr.gov/current/title-10/chapter-I/part-20/subpart-D

 Subpart F – Surveys and Monitoring (Reta Zeto & Spencer Hill):

o The NRC Regulations Title 10, Code of Federal Regulations Chapter 20, covers the
standard for protection against radiation. Subpart F discusses surveys and monitoring.
The general 20.1501 information section covers how each licensee is required to make
surveys of areas including the subsurface that is necessary for the licensee to follow with
the regulations.1 The regulations need to be reasonable to evaluate the magnitude of
radiation levels and the concentrations and quantities of residual radioactivity and the
radiologic hazards of the levels of radiation and left-over radioactivity detected.
Regardless of 20.2103(a), the records from the surveys that describe the location and
amount of residual radioactivity that was at the site must be kept with records important
for decommissioning, and these records must be retained with sections 30.35(g), 40.36(f),
50.75(g), 70.25(g), or 72.30(d).1 The licensee has to make sure that instruments and
equipment used for the radiation measurements, for example the dose rate and effluent
monitoring, are calibrated for the radiation that is measured. Every personnel dosimeter
(except for direct and indirect reading pocket ionization chambers and the dosimeters
used to measure the dose to the extremities) require processing to determine the radiation
dose and that are used by licensees to comply with 20.1201. Conditions that are specific
within the license must be processed and evaluated by a dosimetry processor that holds
accreditation from the National Voluntary Laboratory Accreditation Program and is
approved in this accreditation process for the type of radiation included in the NVLAP
program that most closely approximates the type of radiation for the person wearing the
dosimeter is monitored.1
o Subpart F also discusses when monitoring of radiation exposure is necessary. Each
licensee is responsible for monitoring occupational exposure to the employees working
under that licensee. They are also required to provide and enforce the use of an individual
monitoring device for each person meeting certain criteria. People to receive a
monitoring device from external radiation include:
 1. Adults with the possibility to get above 10% of the total effective dose allowed
annually
2. Minors with the possibility to get a deep dose of 0.1 rem, a lens dose of .15 rem,
or a shallow dose of 0.5 rem
3. Pregnant women with the possibility to get a deep dose of 0.1 rem for the duration
of the pregnancy
4. Individuals entering high radiation areas
o Each licensee is also responsible for monitoring the occupational intake of radioactivity
including radioactive materials in air and Radionuclides in the body or excreted by the
body. People to receive a monitoring device from internal radiation such as these include:
1. Adults with the possibility to get above 10% of the ALI (Annual limit on intake)
2. Minors with the possibility to get an effective dose of 0.1 rem
1. Pregnant women with the possibility to get an effective dose of 0.1 rem during the
entire pregnancy
o All the occupational dose limits apply to a pregnant worker as long as they do not exceed
the embryo/fetus dose limit.1 Whichever dose limit is reached first, is the cut off for that
worker.

1. 10 CFR Part 20 Subpart F. Code of Federal Regulations. Updated October 9, 2002.

Accessed May 31, 2022 https://www.ecfr.gov/current/title-10/chapter-I/part-20/subpart-
B/section-20.1101

 Subpart G - Control of Exposure From External Sources in Restricted Areas (Carissa

Rivinius & Todd Baumgartner):
o Subpart G of the CFR Part 20 discusses the controls which are required to prevent
unauthorized entry and radiation overexposure within high radiation areas. The
entrances to such areas are required to have specific safety features such as the ability
to rapidly reduce radiation levels upon entry to a point where an entrant would not
receive 0.1 rem/hr at 30 cm from a radiation source or surface between the individual
and radiation, alarms that would visibly or audibly signal entry to the entrant as well
as the designated licensee, and locks that are engaged when entry is unwarranted.
 However, these requirements can be substituted by a constant surveillance system
overlooking the entry points. Licensees can also apply for other access regulators
through the NRC.
o Along with maintaining regulations on entry to the high radiation areas, it is
imperative for licensees to ensure anyone within the area can exit safely at any point.
The afore-mentioned safety features are deemed unnecessary when dealing with
packaged radioactive material that will be in an area for less than 3 days, have a dose
rate of less than 0.01 rem (0.1 mSv) per hour at 1 meter from the package’s surface,
or present personnel are properly trained and will prevent radiation exposure to other
individuals from exceeding the recommended dose limits and maintaining the
ALARA principle.1
o For areas where radiation levels could be 500 rads (5Gy) or more in 1 hour at 1 meter
from radiation source or surface, additional measures should be implemented to
ensure individuals cannot gain unauthorized or inadvertent access.2 Subpart G is
critical in its guidance for radiation safety measures for brachytherapy since it sets up
regulations that would apply during a brachytherapy procedure as well as for storage
of brachytherapy sources.

1. 10 CFR Part 20 Subpart G. Code of Federal Regulations. Updated May 20, 2022.
Accessed May 31, 2022.
https://www.ecfr.gov/current/title-10/chapter-I/part-20/subpart-B/section-20.1101
2. 20.1602 Control of access to very high radiation areas. U.S.NRC Website. Updated
March 24, 2021. Accessed May 28, 2022. https://www.nrc.gov/reading-rm/doc-
collections/cfr/part020/part020-1602.html