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Since its inception in 1977, part 21 has presented compliance challenges to licensees, vendors, and the NRC staff.  The NRC staff has noted a high rate of repetitive inspection findings related to part 21, including commercial-grade dedication findings, despite the staff’s attempts to clarify requirements through generic communications and extensive outreach efforts.  Recent part 21 exemption requests by nonreactor facilities further underscore the need to examine part 21. In 2010, the staff established an agency wide working group to further explore these inspection findings and identify part 21 potential areas for improvement. This rulemaking effort is intended to improve the clarity of part 21 while maintaining the original intent of the rule and minimizing changes to currently compliant programs.