GLs and GCs

[ehsnet!hps (HPS)]

Reply-to: Wes.Dunn@p2.f13.n233.z1.fidonet.org (Wes Dunn)
Fido-To: hps

Ok, this is a real regulatory-type response.  It would be official, except our regs only allow that to be from the Office of General Council.  Note that I have some expertise in this area, especially since Texas has spent the past 2 years totally reviewing and revising General Licensing (GL) to incorporate our General License Acknowledgement (GLA) program.

First, very few people, including regulators and manufacturers, understand the GL concept.  I'll stick to the rules pertaining to GC's (approximately: certain measurement and gauging devices) to simplify things.

Second, all sealed sources and devices are (supposed) to be reviewed and listed in the Registry of Sealed Sources and Devices (SSD), maintained by the NRC.  The manufacturer, at the time of registration, requests authorization for the device to be distributed under a GL, a Specific License (SL) or both.

GL devices are defined by their mode of distribution.  If the device is distributed under a GL, in accordance with the distributor's SL, it is a GL device and the possessor is required to handle that device in accordance with the GL.  Note that the device MUST have a GL tag which basically says: I'm a GL device, and don't remove this tag (actual wording is proscribed in the regs.  You can look them up).

As such, a GL device is NEVER covered by the recipient's SL, even if your regulator tells you otherwise.  In fact, even if it is listed on the SL.  It doesn't matter, since the GL takes precedence.  It would have to be redistributed by the manufacturer and the GL tag properly removed.  Note that what constitutes these last two items are ill-defined.  

So, check each GC to see if it has the GL tag.  If it does, you better familiarize yourself with the proper care and feeding of a GL device (i.e., not much) by reading the specific sections of the regulations on GL devices AND the information provided by the distributor.  Call them if you have any questions (not that they know any more than you do, in most cases).

Let me know if you have any questions or comments.

Wesley M. Dunn, CHP, Chief
Medical and Academic Program
Licensing Branch
Division of Licensing, Registration and Standards
Bureau of Radiation Control
Texas Department of Health
512-834-6688
(wdunn@brc1.tdh.texas.gov)
(And, would you belive it, I still get mail....)

(Actually, if you are a Texas licensee, Phil Shaver, Chief, Special Projects Program, etc..., is in charge of our GLA program)


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 * Origin: Health Physics Liberation Front  (1:233/13.2)
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