[ RadSafe ] Exempt Quantity source shipments

Geo>K0FF GEOelectronics at netscape.com
Fri Jul 24 19:17:26 CDT 2009

Cary said:
"I think that you are taking a rather broad definition of transfer as it 
relates to Dan's
initial question about shipping the sources....   Transfer in the NRC 
regulatory sense relating
to exempt sources is transfer of ownership not transport".

Yes I agree that Dan is not transferring ownership, we did not know that at 
first, and I also agree that all he has to do is follow the appropriate
transportation rules (of which I know nothing).

The broader question concerns any unlicensed individual who wants to give 
away, for no commercial gain, one or more exempt quantity source.

This seems to have exposed two camps. One camp says you can do anything you 
wish with an exempt quantity source, the other camp thinks you
can do many things, certainly not anything, especially going to the issue of 
giving them away.

I personally want to find out if what I have been told all these years, i.e. 
one can disposed of such items but not transfer them to anyone else.

This is so serious an issue that a manufacturer who recently sent a customer 
an item he didn't want, told him that he could not return the item, since 
would be transferring without a license.

My  situation is that I wish to donate a quantity of check discs to a 
college specializing in RP training, but have been told by everyone asked 
that it is illegal.

We see that the words "commercial distribution" now actually mean 
"introducing into the marketplace, irrespective of payment or not".

Perhaps somewhere there is a definition of "introducing into the 

George Dowell

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