[ RadSafe ] interesting new question

Clayton J Bradt CJB01 at health.state.ny.us
Fri Oct 29 10:01:29 CDT 2010


Good question. The answer is complicated:

Radiation equipment emitting less than 0.5 mR per hour 5 cm from the 
surface is specifically exempt from regulation under Part 16 of the NYS 
Sanitary Code.  But the Public Health Law (which authorizes publication of 
the Sanitary Code) states "only licensed practitioners (i.e. physicians, 
dentist, podiatrists, P.A.s) and persons licensed under this article (i.e. 
x-ray techs) are permitted to apply ionizing radiation to human 
beings...".  So taken together this means that the exempted radiation 
equipment under Part 16 cannot be used to apply ionizing radiation to 
humans. 


Clayton J. Bradt
Principal Radiophysicist
NYS Dept. of Health
Biggs Laboratory, Room D486A
Empire State Plaza
Albany, NY 12201-0509

518-474-1993




Dan W McCarn <hotgreenchile at gmail.com> 
10/29/2010 10:18 AM

To
"'Clayton J Bradt'" <CJB01 at health.state.ny.us>
cc

Subject
RE: [ RadSafe ] interesting new question






Clayton, if the doses are irrelevant, does this also mean that anyone
sitting in front of a cathode-ray tube (e.g. TV, computer screens) are
subject to these same rules? I thought the issue years ago was to reduce
cathode-ray exposure to "acceptable" limits.

http://www.epa.gov/radtown/tv-computer.html 

Dan ii

--
Dan W McCarn, Geologist
108 Sherwood Blvd
Los Alamos, NM 87544-3425
+1-505-672-2014 (Home - New Mexico)
+1-505-670-8123 (Mobile - New Mexico)
HotGreenChile at gmail.com (Private email) HotGreenChile at gmail dot com


-----Original Message-----
From: radsafe-bounces at health.phys.iit.edu
[mailto:radsafe-bounces at health.phys.iit.edu] On Behalf Of Clayton J Bradt
Sent: Friday, October 29, 2010 08:01
To: radsafe at health.phys.iit.edu
Subject: Re: [ RadSafe ] interesting new question

The use of x-ray producing devices is regulated by the states.  As was 
states previously, FDA has regulations for the manufacture of such 
devices, but the users of the devices do so under state authority.  In New 

York State, the public health law states (roughly) that it is illegal for 
anyone other than a licensed practitioner to apply ionizing radiation to 
humans.  Unless the operator of one of these backscatter vans is a 
physician, PA, dentist, podiatrist, or x-ray technician working under the 
direction of a physician, their use for irradiating humans is strictly 
forbidden.  The doses involved are irrelevant.  Furthermore, any medical 
professional ordering the use of x-ray equipment on humans for purely 
security reasons (i.e. no medical benefit to the patient) would probably 
risk loss of his/her license to practice.  More importantly, the resulting 

malpractice suits would bankrupt the insurance companies.


Clayton J. Bradt
Principal Radiophysicist
NYS Dept. of Health
Biggs Laboratory, Room D486A
Empire State Plaza
Albany, NY 12201-0509

518-474-1993

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