Re: Tracking Exempt Sources

["Dale E. Boyce" <dale@radpro.uchicago.edu>]

Wes,

There are several ambiguities in the regs on exempt status, and this
is the reason that regulators and licensees are confused.  To 
COMMERCIALLY distributed exempt quantities requires a license to
distribute EXEMPT quantities.  The regs (except as they have been
altered in certain agreement states) state that anyone may received
exempt quantities.  I have been told by regulators that exempt
quantities may be distributed to nonlicensees without a license to
distribute exempt quantities as long as it is not done for commercial
purposes.  Operationally, both exempt and generally licensed sources
are often force onto specific licenses.  It shouldn't happen because
it is difficult for radiation safety staff to pull them into
control, and it shouldn't happen BECAUSE they are EXEMPT or GENERALLY
licensed.  Unfortunately it does happen, because the regulations
are not symmetric.  There are tighter restrictions on distribution than
on receipt (for good reason I believe), but when the regs are not self
consistent, it often is up to the field staff to make a call.

Just my musings on a subject that amounts to about 5% of the sources
and solutions we receive.

Dale