Licensing of C-14

["Pickett, Bruce D" <Bruce.Pickett@PSS.Boeing.com>]

My company has purchased several light measuring devices (which we refer
to as photometers) that were manufactured and distributed under a
general license in California. These photometers contain sealed sources
with 50 microcuries (1.85 MBq) of carbon-14. One hundred microcuries
(3.7 MBq) of C-14 is an amount normally exempt from licensing, however,
California requires that these photometers with half of the exempt
amount be distributed under a general license.

On the bottom of the photometers are "Caution Radioactive Material"
labels which provide information pertinent to licensing (see copy at end
of message). The third sentence of the label states "This device shall
not be transferred, abandoned, or disposed of except by transfer to a
person holding a specific radioactive material license to receive this
device." So even though this material would normally be exempt from
licensing, and the manufacturer sold it to my company under a general
license, if I sell it or otherwise transfer it to someone else, THEY
have to have a SPECIFIC LICENSE! 

The requirement for someone to have a specific license for 50 µCi of
carbon-14 in a sealed source seems excessive. Has anyone run into
similar situations? Does anyone have any insight into this requirement?

Bruce Pickett
The Boeing Company, Seattle, WA
bruce.d.pickett@boeing.com


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CAUTION: RADIOACTIVE MATERIAL

This device has been manufactured for distribution as a generally
licensed device under California State Department of Public Health
License 2189-70GL to Photo Research, Division of Kollmorgen Corporation.
The receipt, possession, use, and transfer of this device are subject to
a general license or equivalent, and the regulations of the U.S. Nuclear
Regulatory Commission or Agreement States.
This device shall not be transferred, abandoned, or disposed of except
by transfer to a person holding a specific radioactive material license
to receive this device. 
Service involving sealed sources used in this device shall be performed
only by persons specifically licensed to provide this service.
This device and the sealed radioactive light source contained therein
need not be tested for any purpose.
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