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Re: Americium Source - Special Form?
10CFRPart 30 authorizes possession of smoke detectors under a broad exemption as specified below. The exemption provides covers persons who
".. initially transfer for sale or distribution " these devices (excluding the manufacturer, who must be licensed). Similar wording appears
for exit signs elsewhere. These exemptions apparently do not cover subsequent transfer of the devices. The exemption only applies for
transfers from a licensee specifically authorized to manufacture for that transfer.
Which begs the question: what about when it is waste or in a landfill? Does the exemption continue to remain in effect?
My opinion only, etc.
Steve Cima
cima@bellsouth.net
§30.20 Gas and aerosol detectors containing byproduct material.
(a) Except for persons who manufacture, process, produce, or initially transfer for sale or distribution gas and aerosol detectors containing
byproduct material, any person is exempt from the requirements for a license set forth in section 81 of the Act and from the regulations in
parts 20 and 30 through 36 and 39 of this chapter to the extent that such person receives, possesses, uses, transfers, owns, or acquires
byproduct material, in gas and aerosol detectors designed to protect life or property from
fires and airborne hazards, and manufactured, processed, produced, or initially transferred in accordance with a specific license issued
pursuant to §32.26 of this chapter, which license authorizes the initial transfer of the product for use under this section.
(b) Any person who desires to manufacture, process, or produce gas and aerosol detectors containing byproduct material, or to initially
transfer such products for use pursuant to paragraph (a) of this section, should apply for a license pursuant to §32.26 of this chapter, which
license states that the product may be initially transferred by the licensee to persons exempt from the regulations pursuant to paragraph (a)
of this section or equivalent regulations of an Agreement State.
[34 FR 6653, Apr. 18, 1969, as amended at 40 FR 8785, Mar. 3, 1975; 43 FR 6921, Feb. 17, 978; 52 FR 8241, Mar. 17, 1987; 58 FR 7736, Feb. 9,
1993]
Keith Welch wrote:
> <HTML>
> Robert,
>
> <P>I had the same question - I always thought that's what general licenses
> were for, so we could own nominal amounts of it without violating a requirement
> for specific licensing - can one of the NRC regulatory gurus straighten
> me out on that, It's never been clear to me .... but -
>
> <P>I don't think your smoke detector source is Special Form - somebody
> correct me if I'm wrong.
> <BLOCKQUOTE TYPE=CITE>
> <PRE>Does this mean I can't TRANSFER, RECEIVE, POSSESS, USE.....etc my smoke detector, which contains a special form Americium-241 source?
>
> Or my tritium illuminated watch and compass?</PRE>
> </BLOCKQUOTE>
>
>
> <P>--
> <BR>Keith Welch
> <BR>Thomas Jefferson National Accelerator Facility
> <BR>Newport News VA
> <BR>welch@jlab.org
> <BR>Ph: (757)269-7212
> <BR>FAX:(757)269-5048
> <BR> </HTML>
>
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