29 CFR 1910.96 follow-up question

[John Moulder <jmoulder@post.its.mcw.edu>]

> >We put in a number of grant proposals to the US Army Breast Cancer 
> >Research Program.  Now we need to file a "Memorandum of Environmental 
> >and Safety Analysis".   Among the long list of documentation they want 
> >is the following item: 
> > 
> >"(9) Provide the following information concerning compliance with 
> >regulatory requirements if the proposed research involves the use of 
> >ionizing and non- ionizing radiation: 
> >     (a) Ionizing radiation, in accordance with 29 CFR 1910.96, which 
> >includes radioactive materials and x-rays 

Thnks to help from the mailing list, I now have the regs and know that these 
are the OSHA radiation regulations, and that they largely parallel NRC rules, 
except that thay apply to users of non-NRC regulated radiation sources (x-ray 
machines, linacs, etc).

Question for university RSOs with x-ray machine and linac users:  Do you 
regulate your users of non-NRC radiation sources the same way you regulate 
the users on NRC-regulated radiation soruces?  If not, what are the 
differences?  

John Moulder (jmoulder@its.mcw.edu)          Voice: 414-266-4670
Radiation Biology Group                      FAX: 414-257-2466
Medical College of Wisconsin, Milwaukee