Part 33 proposal

[slaback@micf.nist.gov]

Comment: for those who have not yet looked
this up, beware, this proposal could have as
much impact on your program as the Part 20 revision.

My favorite item is a new 33.25(b), "A licensee ...
is responsible for the acts and omissions of the
supervised individual."  There is no qualification
of reasonable, standard-of-performance, etc., to
exclude totally irresponsible acts.  It adds a
new meaning to liability.

A question:  While the current and the proposed
Part 33 exclude Part 35 type activities, there are
repeated references to medical type licensed 
activities, e.g., "33.21(a) ... for medical broad 
scope licensees ...."
Is Part 33 in fact used for medical licensee activities?
If so, why are these not covered by Part 35?
Is there a reson why these cannot be mutually exclusive?
Put this down for the dumb question of the day.

A little risk adds spice to life.
Lester.Slaback@NIST.gov