Part 33 proposal

[JMUCKERHEIDE@delphi.com]

Les, 

What about the postal employee who brings a rifle to work :-)

> 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.

Are we revisiting the "double standard" for good (medical) and bad (industry)
radiation? 

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

Thanks.

Regards, Jim Muckerheide
jmuckerheide@delphi.com