RE: Wipe test requirements under 49 CFR 173.424, etc.

[Craig Reed <CReed@novoste.com>]

49CFR173.4439(a) actually says "methodology".   The probl 

-----Original Message-----
From: LRGreger@aol.com [mailto:LRGreger@aol.com]
Sent: Saturday, February 19, 2000 3:38 AM
To: Multiple recipients of list
Subject: Re: Wipe test requirements under 49 CFR 173.424, etc.


In a message dated 02/18/2000 8:45:43 AM Pacific Standard Time, 
CReed@novoste.com writes:

<< For the return of an "undamaged" article, the Distributor (or general
 licensee) could petition for an exemption allowing a visual inspection
 for damage in lieu of the test methodology required by 173.443(a).  The
 exemption might not grant relief for allowable transferrable
 contamination, but it could resolve the non-compliance for the missing
 survey. 
 
 Craig Reed >>


Craig,

Correct me if I'm wrong, but I don't believe that 49CFR173.443 specifies
a 
test methodology.  I'm working off of memory now because I'm at home.  I

provided Clayton an "unofficial" DOT interpretation on this subject on 
another list (from work computer), which I also don't have readily
available 
now.   DOT essentially said that reasonableness is allowed (refreshing),
such 
that if there is no credible threat of contamination and/or radiation
levels, 
then actual measurements do not have to be made.  Examples would be
sealed 
sources for which routine leak tests have shown no leakage, and low dose

potential devices such as x-ray fluorescence devices, among others.

Rob Greger
California Radiologic Health Branch
lrgreger@aol.com
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