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RE: [Fwd: Re: You can't have too much NVLAP.]



On 6 May 2003 at 16:21, willim01@mskcc.org wrote:



> If a ED can meet certain stds, it should be permitted for use as a 

> dose of record.  



Hi Matt,



I agree with the above. One of the reasons I submitted the petition for rulemaking is 

that there has been a NRC policy that an ED can be used as a dose of record, and 

that the only requirement is that the on-site inspector can evaluate the program. I 

addressed that in the petition. The fact is the NRC inspector is not trained to assess 

an ED in a dosimetry program, as would be a NVLAP assessor. The NRC in many 

documents and various forums stated that while the ED can be sued as dose of 

record, due to the 10 CFR 20.1501(c) exclusion, they had reservations regarding its 

use as dose of record. 



I am now giving them an opportunity to right a wrong that has been long overdue.





***************************************************************

Sandy Perle                           

Director, Technical                           

ICN Worldwide Dosimetry Service     

ICN Plaza, 3300 Hyland Avenue   

Costa Mesa, CA 92626             



Tel: (714) 545-0100 / (800) 548-5100  Extension 2306 

Fax: (714) 668-3149  



E-Mail: sperle@icnpharm.com      

E-Mail: sandyfl@earthlink.net                      

                 

Personal Website: http://sandy-travels.com/

ICN Worldwide Dosimetry Website: http://www.dosimetry.com/



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