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An Illuminating Note on Products Containing Small Amounts of Radioactive Materials

Amy C. Roma

Amy C. Roma,

Washington, D.C.

Ajay Kuntamukkala

Ajay Kuntamukkala,

Washington, D.C.

Daniel Stenger

17 December 2015
The U.S. Nuclear Regulatory Commission recently issued a proposed civil penalty of $28,000 to a watch seller for apparent violations of requirements related to importing and distributing watches containing radioactive material. The watches contain a small amount of tritium encapsulated in glass vials, which enables the markers on the watch face and hands to glow and be seen in low light.

The NRC found the company imported watches and distributed them in violation of the NRC’s import and distribution regulations. Tritium watches are exempt from NRC regulation once they are initially distributed, but the initial distribution must be made under an NRC license to ensure that the devices meet safety requirements. The NRC alleges that the company was selling a watch that it was not authorized to sell under its NRC license and failed to make required reports to the NRC.

Many products contain low levels of radioactive materials and are subject to similar requirements, such as irradiated gemstones, for example. The proposed fine is on the high end for the NRC and may reflect that the NRC is trying to send a message for these types of licensees. In situations like these, a robust response to the NRC’s Notice of Violation, combined with appropriate corrective actions, could help reduce the NRC’s proposed civil penalty.

Amy C. Roma

Amy C. Roma,

Washington, D.C.

Ajay Kuntamukkala

Ajay Kuntamukkala,

Washington, D.C.

Daniel Stenger

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