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Review 10 CFR Part 20, subparts B, C, D, F and G. Summarize the pertinent parts for your
classmates on how it applies to brachytherapy.

Subpart B (Jenny)
Subpart B discusses the radiation protection programs.
Section § 20.1101 specifies that each licensee is required to document and ensure proper
implementation of radiation protection program.1 The program measures the complexity and the
degree of risk to the workers and the public from radiation. The licensee must practice follow the
guideline of As Low As Reasonably Achievable (ALARA) to reduce exposure to radiation
workers and public. At least once a year, the licensee must review the radiation protection
program. This review should cover procedural compliance, technical adequacy, implementation,
and effectiveness of the program. Results from this review should include lessons learned and
suggested improvements.2 To ensure ALARA implementation, each licensee must establish a
dose constraint of no more than 10 mrem (0.1 mSv) per year from radioactive air emissions.1 If
the dose constraint is exceeded, the licensee must report and take appropriate action to prevent
recurrence. Radon-222 and its daughters are not expected to receive a total effective dose
equivalent in the dose determination.

Subpart C 20.1201-02 (Jason)

Subpart C of 10 CFR Part 20 addresses the standards and regulations for occupational
dose limits. Section 20.1201 discusses occupational dose limits for adults1 while section 20.1202
provides the compliance requirements for licensees who may need to provide a sum total of
internal and external radiation doses.21
Section 20.1201 states that annual occupational dose limits will be no greater than 5 rems
for the total effective dose equivalent of the individual or no greater than 50 rems to any singular
organ or tissue with the exception of the lens of the eye.1 The lens of the eye can receive no
greater than 15 rems annually. Another exception for occupational dose would be any dose
accrued during a planned special exposure under section 20.1206. However, if an individual’s
occupational dose goes above the previously described limits that dose must be recorded and
subtracted from that individual’s dose limitations for planned special procedures for the current
year and the remainder of their lifetime. To track occupational dose it will be measured from
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personal monitoring devices and in some cases surveys, radiation detectors and derived air
concentration (DAC) values. Additionally, a licensee must limit their soluble uranium intake to
10 mg per week. Lastly, a record of an individual’s occupational dose will remain with them
even if they are hired by a different employer in the recording year.
Section 20.1202 begins by acknowledging that some licensees are required to sum
external and internal doses while some are not. Licensees can find which category they fall under
in sections 20.1502 (a) and (b) of the 10 CFR Part 20.1 Section 20.1202 was created to establish
compliance standards for individuals who are required to sum their internal and external dose
exposure. The section distinguishes the intake of radiation dose by inhalation, oral ingestion and
intake through openings or absorption in the skin. Dose from intake by inhalation of
radionuclides cannot have a result greater than one when dividing the deep-dose equivalent by
the total effective dose equivalent in sum with other variables such as the annual limit on intake
(ALI), DAC and others involving irradiated organ or tissue fractions. Intake by oral ingestion
must be accounted for if the dose ingested is greater than 10 percent of the ALI for this category.
Intake through open wounds or absorbed through the skin should be evaluated by the licensee to
determine the appropriateness of reporting the dose.
In reflection, section 20.1201 sets a foundation for occupational dose limits for adults
while section 20.1202 is used as a filter to be utilized by occupational workers that may need to
sum internal and external doses. Both of these sections apply to brachytherapy because the use of
sources to perform brachytherapy treatments creates a hazardous work environment where a
worker could expose themselves to an excessive amount of dose. These amounts need to be
recorded to enforce current safety regulations and provide the groundwork for improving
radiation safety in the workplace.

Subpart C 20.1203-04 (Nathan)

Subpart C 20.1203 refers to external dose from airborne radioactive material.1 This
section specifies how to control and assess radiation exposure from the airborne cloud to the
external body. This includes all of the exposed portions of the body. Each of these tissues as well
as the lenses of the eye need to be taken into account to give an overall composite dose to the
individual. The radiation from the radioactive cloud that the section refers to is not directly
involved with brachytherapy since the majority of sources that we deal with are sealed and
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therefore do not have airborne contamination. An exception to this may occur in the event of an
explosion where the sealed source is unsealed and an airborne cloud of radioactive material is
formed.
Section 20.1204 is in reference to any internal dose assessments of the individuals.1 This
internal radiation may be inhaled, injected, or consumed. The radiation dose from this internal
radiation becomes much more complicated as the body processes the radioactive source in many
different ways. The radiation contribution will need to take into account how much radiation
each organ of the body is absorbing as it passes through the body. All of these doses need to be
considered when coming up with the committed effective dose equivalent to the individual.2 3
Again this is not strictly assessed in brachytherapy. An exception to this may be if somehow a
source is accidentally consumed or if a worker accidentally injects himself with radioactive
isotopes.

Subpart C 20.1206-07 (Dan)

Subpart C of 10 CRF Part 20 contains a variety of information covering occupational
dose limits. This includes dose constraints for the general population, minors, and equivalent
doses to the fetus/embryo. It is essential to have these dose limits in place to protect the general
population from harmful radiation. Sections 20.1206-07 further explain this subject matter.
20.1206 Planned special exposures
As the title indicates, this section covers special exposures. It is made clear that special
exposures should only be used when the alternative is unavailable or impractical. In order to
move forward with a special exposure, licensees must authorize it in writing beforehand.
Individuals must be informed of the purpose of the operation along with the estimated doses and
potential risks. As is the case with most radiation exposures, ALARA must be followed closely.
Before allowing someone to participate in a special exposure, prior lifetime doses must
be acquired for each involved person. The licensee must not plan an exposure that exceeds the
dose limits in a year. The provider must also maintain records of the special exposure as is stated
in 20.2105. They must also submit a written report as is mentioned in 20.2204. At the end, the
licensee must record an estimation of the dose from the special exposure and inform the involved
individual within 30 days of the exposure.
20.1207 Occupational dose limits for minors
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This section is very short. It simply states that the annual occupational dose limit for
minors is 10 percent of the dose limits for adult workers mentioned in 20.1201.

Subpart C 20.1208 (Karen)

Part 20.1208 Dose equivalent to an embryo/fetus.
This section discusses the radiation safety guidelines concerning pregnant women and
their embryo/fetus. For a declared pregnant woman, the dose equivalent to the embryo/fetus over
the course of the entire pregnancy should not exceed 0.5 rem (5 mSV) due to occupational
exposure.1 This section only gives dose restrictions to declared pregnant women and their
embryo/fetus but does not review specific working conditions. Efforts must be made to assure
that this dose is distributed uniformly over the entire period of pregnancy to prevent exceeding
the 0.5 rem. Restricting dose to the fetus does not necessarily mean pregnant women need to
avoid work with radiation or radioactive materials, however, the employer and employee should
carefully review the exposure conditions of the pregnant women. Their working conditions
should be such that the probability of high accidental doses or radionuclide intakes is
insignificant.
Practices to maintain ensure doses remain ALARA should be employed at all times.
Minimize time, maximize distance and use shielding whenever possible. Once the employee is
declared pregnant, additional monitoring of both mom and the embryo/fetus is tracked.1 An
additional dosimeter may be issued to the employee to wear in the abdominal region. Under 10
CFR 20.1208, if the dose already received exceeds 5 mSv (500 mrem) or if it is within 0.5 mSv
(50 mrem) of the 5 mSv (500 mrem) dose limit at the time of declaration, the allowable exposure
is restricted to an additional 0.5 mSv (50 mrem).

Subpart D (Brianne)
Subpart D of 10 CRF Part 20 is established to protect the public from unnecessary
radiation exposure and limit dose to individuals of the public. There are many employees and
general public traffic that use the hallways and waiting rooms of radiation oncology departments.
Therefore subpart D CRF Part 20 has put in place detailed regulations by the NRC to avoid
detrimental effects of radiation exposure to the public and other hospital or clinic employees who
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may be unaware of the dangers of radiation. Any exposure received that is considered
unnecessary for and individual is controlled by the NRC and described below.
20.1301 Dose limits for individual members of the public
The subpart, states that the total effective dose equivalent to individual members of the
public does not exceed 0.1 rem (1mSv) in one year.1 Patients who are receiving radioactive
treatments are allowed visitors if the dose to visitor does not exceed 0.5 rem.1 Dose to the visitor
is allowed to surpass 0.1 rem. These instances must be authorized by the user as defined in 10
CRF Part 35.1 For Sscenarios when the dose limit to a member of the public member is increased
to 0.5 rem, special documentation from the facility is necessary. This documentation includes the
duration of time needed for the dose increase, why the increase in dose was needed, and how the
facility addressed controlling the dose to such individuals.1
20.1302 Compliance with dose limits for individual members of the public
In order to regulate dose to the general public and employees, facilities must, as a
baseline, monitor radiation levels in unrestricted areas, controlled areas, and levels of radioactive
materials within the department as a baseline.1 It is the responsibility of the facility to submit
documentation of the total effective dose equivalent and prove it was not surpassed by the limits
set in 20.1301.1 The annual average concentrations for radioactive material released in gaseous
and liquid effluents at the boundary of the unrestricted area cannot exceed the values found in
Table 2 of appendix B to part 20.1

Subpart F (Amber)
Subpart F discusses the measuring and monitoring of radiation sources.1 According to
section 20.1501, a licensee is responsible for surveying all of the places where there is or has
been a significant amount of radiation.1 They should evaluate potential radiological threats and
surfaces that have held radioactive materials.1 When measuring the radioactivity, the licensee
needs to keep a record of the instances when they have detected residual radiation on any
surfaces, describing the site and amount of radioactivity found.1 They will also need to make
sure that the equipment used to survey the radiation is properly calibrated.1 Film badges and
other personnel dosimeters should be processed and assessed to keep track of dose received to
individuals.1 Finally, the licensee is responsible for complying with the National Voluntary
Accreditation Program (NVLAP). 1
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Section 20.1502, discusses circumstances that necessitates monitoring of occupational

dose.1 The licensee is responsible for giving devices to adults that have a chance of receiving
dose greater than 10% of set restrictions within 20.1201 during one year.1 Minors and pregnant
women require devices if their deep dose is greater than or equal to 0.1 rem during a year’s
time.1 Children also need a monitor if their expected shallow dose is greater than 0.5 rem or lens
dose of 0.15 rem.1 They should also track the dose of any individual entering a site that contains
large amounts of radiation.1 The licensee should track and evaluate the dose for all of these
individuals.1
These rules are essential to follow during brachytherapy treatments because the
individuals that are handling the sources will need to wear monitoring devices. The room and
surfaces that the radiation sources come into contact with will also need to be surveyed before,
during and after procedures.

Subpart G (Nancy)
Subpart G summarizes control of exposure to radiation sources in restricted areas.
Section 20.1601 addresses high radiation areas, while 20.1602 addresses very high radiation
areas.
Section 20.1601 specifies that there must be a way to decrease the exposure, activate a
visible or audio alarm and/or lock access to high radiation areas.1 The above can be replaced
with a monitoring system that restricts access. The licensee can apply for alternative systems for
restricting access. The restriction to access must not impede exit from these areas. Areas
designated for packaging and transportation of high radiation sources do not need restricted
access as long as packages do not remain in these areas for more than 3 days and the dose rate
1m away from the package does not exceed 0.01 rem/hr. Restriction to hospital rooms containing
radioactive patients is not required as long as there are attending personnel taking precautions to
limit exposure of others to the patient.
Section 20.1602 specifies in addition to section 20.1601, individuals must not be allowed
unauthorized or inadvertent access to areas of radiation with potential exposure greater than 500
rads in 1 hour at 1 m.1

References:
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1. The United States Nuclear Regulatory Committee. Part 20 - Standards standards for
Protection protection Against against Radiationradiation. The United States Nuclear
Regulatory Committee. [Web site] 10 CFR Part 20. https://www.nrc.gov/reading-rm/doc-
collections/cfr/part020/. Updated June 04, 2018. Accessed July 11, 2018.
2. Zelac RE, Cameron JL, Karagiannis H, et al. Consolidated guidance: 10 CFR part 20 -
standards for protection against radiation. WebsiteNUREG-1736.
https://www.orau.org/ptp/PTP%20Library/library/NRC/NUREG/1736.pdf. Published
October, 2001. Accessed July 16, 2018.
3. Cember H, Johnson TE. Introduction to Health Physics. 4th Ed. New York, NY: McGraw-
Hill; 2008.