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Re: Accelerator vs. X-ray unit
Steve,
New Jersey issued particle accelerator regulations several years ago.
These regulations define a particle accelerator to be "any machine
that acclerates charged particles (electrons, protons, deuterons, or
other charged particles, etc.) in a vacuum and discharges the
resulting particulate or other radiation but which does not meet the
specifications of machines currently regulated under N.J.A.C. 7:28-14
through 16 (my note: 14-16 refer to diagnostic x-ray and therapeutic
units); particle accelerators include, but are not limited to,
machines used for research, irradiation or other purposes; such
machines include, but are not limited to, potential-drop
accelerators, electron linear accelerators, cyclotrons, betatrons,
microtrons, ion implant acclerators, and electron microscopes;
particle accelerators do not include high voltage generators,
televisions, video display terminals, cathode ray tubes or other
similar devices whose primary purpose is not the production of a
useful charged particle beam."
New Jersey's particle accelerator regulations exempt particle
accelerators incapable of operating at more than 30 kVp from most of
the particle acclerator requirements. A set of limited requirements
are set out for electron microscopes. We haven't had any marginal
particle accelerators here - what we have are clearly what the state
was trying to regulate - so we haven't had any experience with
appealing for a different classification or for exemptions. But if
we did, I suppose I'd write a letter of appeal to the state's
Commission on Radiation Protection. At any rate, I think that under
New Jersey's regulations, you've clearly got yourself a particle
accelerator and would have to comply with all of New Jersey's
particle accelerator requirements for training, survey, instrumentation,
monitoring, control and interlock systems, warning systems, operating procedures,
etc.
Regards,
Sue M. Dupre, Health Physicist
Office of Occupational Health and Safety
Chemical Sciences Building/Forrestal Campus
Princeton University
Princeton, NJ 08544-0710
E-mail: dupre@princeton.edu
Phone: (609) 258-6252
Fax: (609) 258-1804
Visit the OHS Web site at http://www.princeton.edu/~ehs