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Re: Licensing and Use of Smoke Detectors



You limit your verbs to "acquire."  10 CFR 30.20 uses the verbs, "receives,

possesses, uses, transfers. owns, or acquires..."



Regarding your statement, "This regulation you cited does not in any way tell

the recipient how they may or may not use the device once it is in their

hands.":  The key work is "device."  The source without the rest of the smoke

detector is not a "device."  It is byproduce material subject to full NRC

licensing.



I agree that this is open to interpretation, but I'm cautious in such

situations, since I can't predict how a regulator will see it.



The opinions expressed are strictly mine.

It's not about dose, it's about trust.

Curies forever.



Bill Lipton

liptonw@dteenergy.com



"Perrero, Daren" wrote:



> It would appear that you have interpreted that regulation in a very narrow

> way whereas I would read that section as stating "you are exempt from the

> regulations in 20, 30 and 36 through 39 if you acquire Am-241 in a smoke

> detector that was approved by us for distribution following 10 CFR 32.26."

>

> This regulation you cited does not in any way tell the recipient how they

> may or may not use the device once it is in their hands.

>

> Other regulations stipulate what you have to do in order to be authorized to

> manufacture for distribution those products with radioactive materials (Part

> 32).

>

> The thoughts expressed are mine, mine, all mine!

> I'm with the government, I'm here to help........

> Daren Perrero, Health Physicist

> perrero@idns.state.il.us

>

> -----Original Message-----

> From: William V Lipton [mailto:liptonw@DTEENERGY.COM]

> Sent: Thursday, June 20, 2002 6:36 AM

> To: BLHamrick@AOL.COM

> Cc: brees@LANL.GOV; radsafe@list.vanderbilt.edu

> Subject: Re: Rad Sources for Workshops

>

> I don't think so!

>

> The exemption for smoke detectors, in 10 CFR 30.20 is limited:  "..to the

> extent that such [exempt] person receives, possesses, uses, transfers...

> byproduct material in gas and aerosol detectors designed to protect life or

> property..."  If the source is removed from the detector, the exemption is

> lost, and the possession or transfer (i.e., disposal) of the source is

> subject to the requirements of 10 CFR 20.

>

> Once the source is removed, the end user cannot legally reinstall it, since

> he then becomes a manufacturer and requires a specific license from the NRC

> or an Agreement State.

>

> The opinions expressed are strictly mine.

> It's not about dose, it's about trust.

> Curies forever.

>

> Bill Lipton

> liptonw@dteenergy.com

>

> BLHamrick@AOL.COM wrote:

>

> Actually, domestically-produced smoke detectors are usually distributed as

> items exempt from regulation, thus the end user can technically do anything

> they want with them, but I would recommend strongly AGAINST taking them

> apart, as with one microcurie of activity, they contain about 167 stochastic

> ALIs.

>

> Barbara

>

> Barbara



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