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Re:10 CFR 20.1904(b)
Check out NRC Information Notice 97-03, "Defacing of Labels to Comply with
10CFR20.1904(b). It may help you. However, I don't think the notice goes
into much detail of what specifically defines a "label." The notice can be
found at:
http://www.nrc.gov/NRC/GENACT/GC/IN/1997/in97003.txt
For a definition of what exactly constitutes a label, 10CFR20.1904(a) states
that a label shall bear the radiation symbol and the words "Caution, Radioactive
Material" or "Danger, Radioactive Material" (in addition to other information).
Because of this wording, it can be ascertained that defacing of a "label" whould
require removal of the radiation symbol and all associated required wording.
Rodney Bauman, CHP, RRPT
Weldon Spring Site
rodney_bauman@wssrap-host.wssrap.com
____________________Reply Separator____________________
Subject: 10 CFR 20.1904(b)
Author: <radsafe@romulus.ehs.uiuc.edu>
Date: 3/25/99 11:10 AM
I've received a query the RSO at a community hospital in southern California who
is having a disagreement on the interpretation of 10 CFR 20.1904(b). She wrote:
"I interpret 'remove or deface the radioactive material label or otherwise
clearly...' to mean all symbols, words, etc. that refer to radioactivity. Some
package have both the magenta symbol and the word 'radioactive' affixed to them.
"My collegue believes that this refers only to the symbol and the words do not
need to be defaced."
Although obviously both should be removed/defaced, I have been unable to locate
any concrete regulatory (or other) interpretation by searching the NRC website
or the RADSAFE archives. Can anyone out there help?
Thanks in advance. I will forward all replies to the RSO.
Paul R. Steinmeyer
Health Physicist
Radiation Safety Associates, Inc.
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