Re: DOT Regulations

["Wesley M. Dunn" <WDUNN@brc1.tdh.state.tx.us>]

Actually, the answer is fairly simple:

If the physician doesn't transport interstate (e.g., across state
lines), the jurisdiction is with the radiation regulatory agency, not
the DOT.

The NRC and Agreement State regulations generally require intrastate
(in state) transport of radioactive material to still abide by DOT
regulatory requirements.

NOTE: Not every state includes the NRC physician exemption.  Texas,
for one, does not.

Wes



> Date:          Fri, 17 May 96 07:02:06 -0500
> Reply-to:      radsafe@romulus.ehs.uiuc.edu
> From:          lambert@hal.hahnemann.edu
> To:            Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
> Subject:       Re: DOT Regulations

> If the NRC says a physician can transport RAM without regard to DOT
> regulations, and the DOT is mum on the subject, who has jurisdiction?
> Which agency has authority?
>
> If this means as you suggest (and I tend to believe you are right) that
> the physician exemption by the NRC is meaningless, then maybe the NRC
> should change their rule to eliminate conflicting and confusing
> regulations.  (Anybody listening?) Is there a mechanism, short of a
> petition for rulemaking, that an individual or licensee can suggest
> regulatory changes such as the minor one suggested above?
>
> Kent Lambert
> LAMBERT@hal.hahnemann.edu
>

*********************************************************************
Wesley M. Dunn, C.H.P.                     512-834-6688
Deputy Director, Licensing                 512-834-6690 (fax)
(Texas) Bureau of Radiation Control        wdunn@brc1.tdh.state.tx.us
*********************************************************************