[ RadSafe ] NYC permitting of detectors: NYPD proposes some changes.

[Syd H. Levine]

They have rendered the law meaningless within the construct of its own 
twisted logic.  Only a true bureaucrat could conclude any of this makes 
sense, or that there is any point in proceeding with promulgation.

Syd H. Levine
AnaLog Services, Inc.
Phone:  (270) 276-5671
Telefax:  (270) 276-5588
E-mail:  analog at logwell.com
Web URL:  www.logwell.com

----- Original Message ----- 
From: "Clayton J Bradt" <cjb01 at health.state.ny.us>
To: <radsafe at radlab.nl>
Sent: Monday, February 04, 2008 10:57 AM
Subject: [ RadSafe ] NYC permitting of detectors: NYPD proposes some 
changes.



NYPD is drafting some changes in the proposed law and has drafted proposed
regs.  Below are the most relevant passages.  I don't know if these have
been posted anywhere, I couldn't find them on the City Council web site, so
I'm just posting excerpts.

************************************
Proposed changes to Law:


§ 10-802 Permits for possession or deployment of biological, chemical and
radiological detectors.  a.  It shall be unlawful for any person to possess
or deploy a biological, chemical or radiological detector in the city of
New York unless such person holds a valid permit therefor, provided,
however, that the commissioner shall exclude by rule any class or type of
biological, chemical or radiological detector that shall not require such
permit because such detector does not have as a purpose the detection of  a
possible biological, chemical or radiological weapons attack.

**************************************************
Proposed regulations:


§ 20-05 Exceptions.

Notwithstanding the provisions of Chapter 8 of Title 10 of the New York

City Administrative Code, no permit or notification of alarm is required

for the following types of detectors:

      (a) Smoke alarms;

      (b) Carbon monoxide detectors;

      (c) Radon detectors;

      (d) Hand-held or portable radiological detectors or Geiger counters

designed and intended for use by individuals; and

      (e) Detectors which do not have as a purpose the detection of a

possible biological, chemical or radiological weapons attack, and include:

            (i) Detectors possessed or deployed by an accredited academic

or instructional institution in an academic setting, whether in a

laboratory, classroom or in the field, by instructors or students, for the

purpose of academic instruction;

            (ii) Radiation detectors possessed and deployed by hospitals

and other health care delivery settings, except for fixed portal radiation

detectors;

            (iii) Detectors possessed or deployed by utilities or in an

industrial setting for the purpose of monitoring internal air quality or

leakage of hazardous materials; and

            (iv) Detectors possessed or deployed by certified industrial

hygienists and other individuals or entities responsible for or engaging in

testing or monitoring of workplace or environmental safety.

***************************************************************************


As originally written, the law was outrageous and stupid. Now its just
stupid.

Clayton J. Bradt
Assistant Bureau Director
BERP
NYS Dept. of Health
518-402-7550


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