Re: Part 33 proposal

[Kent Lambert <lambert@allegheny.edu>]

slaback@micf.nist.gov wrote:

> 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.

There are many medical broad scope facilities, NIH, and many university 
hospitals for example.  Some aspects of a broad scope license are useful for 
medical institutions, such as the ability to commission and decommission rooms 
were radioactive materials are used or stored, and the ability to add new 
authorized physician users.  Under a "Part 35" license, an amendment is 
necessary to move a nuclear medicine camera room and the NRC must be notified 
whenever a new authorized physician user is added.  Some research using human 
subjects is not permitted under a Part 35 license that is permitted under a 
Part 33 license.  Further, there is only one license and set of license 
conditions to administer, thus relieving the RSO, at least incrementally, of 
some headaches.

I understood that the lack of a definition of a medical broad scope license was 
one of the driving forces behind the proposal to change Part 33.

The annual fee for a medical license is ~$7000, the annual fee for a broad 
scope license is ~$11,000 and the annual fee for a medical broad scope license 
is ~$28,000.  Therefore, the NRC stands to gain ~$10,000 - $17,000 for each 
medical broad scope license.  But that would not be a consideration, would it?

-- 
Kent Lambert, CHP
lambert@allegheny.edu

Then again, I could be wrong.