[ RadSafe ] SSDR's and Licensing

[Bill Rowan]

We've run into a hurdle in the USA with SSDR's and Licensing.  I'm trying to
perform additional due-diligence.  

 

Does anybody have knowledge of the following instance where:

 

"Company A" holds a device registration (for exempt distribution devices )

"Company B" holds the possession and distribution licenses for the product
that is registered by "Company A".

 

We "Company B" have a relationship with a "CompanyA" that has designed a
product which contains nuclear material.  

 

We have proposed to be the "contract manufacturer" that would produce and
distribute Company-A's  product.  Company-A would like to hold the SSDR;
Company-B would like to add this (once registered) product to its possession
and distribution licenses.  The thought is that if the relationship ever
soured, CompanyA could identify other companies who could produce and/or
distribute these items in accordance with the SSDR, companyA & B could
separate and go their respective ways, with no harm to either company.

 

NRC is telling us that either CompanyA or CompanyB must hold all 3 items:
SSDR, Possession license & Distribution license.  

 

If we were to hold the SSDR, the original design firm would have lost
control of their product.  Obviously they are not happy with this situation.
Nor are they familiar with the operation of a nuclear facility.

 

Does anybody have any thoughts on how to protect both companies or have
knowledge where one company holds the SSDR and another holds the licenses to
manufacture and distribute?

 

Thank you.

 

Bill Rowan

Vice-President & General Manager

browan at self-powered.com 

 

Self-Powered Lighting

31 Waterloo Ave

Berwyn, PA  19312 

USA

 

484-595-9130 T

484-595-9135 F