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A Posting Peculiarity

Ulsh, Brant A.; Bradley, Ed

doi: 10.1097/HP.0000000000000661
Operational Topics

The definitions of “radiation area,” “high radiation area,” and “very high radiation area,” provided by the U.S. Department of Energy in 10 CFR Part 835.2, and by the Nuclear Regulatory Commission in 10 CFR Part 20.1003, appear to require redundant posting. This is counterintuitive and would be confusing if the regulations were followed as currently written. We suspect that this is unintentional. However, until the relevant regulations are revised, it is recommended that licensees request written clarification from the regulators to ensure that they are able to demonstrate regulatory compliance.

*M. H. Chew & Associates, 7633 Southfront Road, Ste. 170, Livermore CA 94551‐8211.

Brant Ulsh has over thirty years of academic training and governmental, academic, and private industry work experience in radiation fields including health physics, nuclear engineering, radiobiology, and radioecology. He earned a Bachelor of Science degree in nuclear engineering and a Master of Science degree in health physics, both from the University of Cincinnati, and a Ph.D. in radiological health sciences from Colorado State University. He is also a Certified Health Physicist. Dr. Ulsh is currently a Principal Health Physicist with M. H. Chew & Associates in Cincinnati. He also serves as an affiliate faculty member of Colorado State University and the Northern Ontario School of Medicine. His email address is

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