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Re: Licensing and Use of Smoke Detectors
An IAEA document that helps to understand and to interpret exemption is the
Principles for the Exemption of Radiation Sources and Practices for
Regulatory Control, Safety Series 89, and IAEA, 1988
This specific source is Americium oxide (Chemical form), incorporated in
ceramic cylinder and poses no internal radiation hazard, and care should be
taken to avoid loss of containment or damage.
Jose Julio Rozental
joseroze@netvision.net.il
Israel
----- Original Message -----
From: William V Lipton <liptonw@DTEENERGY.COM>
To: Perrero, Daren <Perrero@IDNS.STATE.IL.US>
Cc: <radsafe@list.vanderbilt.edu>
Sent: Thursday, June 20, 2002 4:02 PM
Subject: 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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