To Whom It May Concern:
I reviewed the NRC proposed rule which directly affects the products my company has designed, manufactured and shipped to end users for more than 40 years. Should this proposed rule pass and require our End Users to possess a Specific License, it will most certainly have a financial impact on my company in the form of lost orders, lost business, business transferred overseas, etc. Equally important is the financial impact it could potentially cause for End Users of my company's equipment (General Licensees).
While I understand and agree with the need to enforce accountability of Generally Licensed Devices (GLD), I do not believe imposing high fees and specific licensing requirements is the solution. I suspect that many General Licensees will opt to dispose of the GLDs instead of pursuing the Specific Licensing strictly based on the fees.
Customers purchase our equipment due to the high reliability and energy-efficiency of our gamma devices. Imposing fees of this nature would certainly force any potential client of my company to reconsider their decision to purchase our equipment. My company's customer base spans from general packaging to large beverage suppliers, all of whom rely on our equipment as part of their quality inspection process.
My company is dedicated to full compliance with all regulatory requirements and we are confident that if General Licensees were held accountable via formal and regular reporting processes, the likelihood of improved device tracking and reporting by General Licensees would increase greatly, without any increase in fees or specific licencing requirements.
As the proud owner of an American business, I urge you to reconsider this matter and come to a more reasonable solution, one that would allow my business and my customers operate efficiently.
Thank you for your time.
Sincerely,
Steve M. Calhoun
President & CEO
2010/11/23-Comment (1) of Steve Calhoun on FR Doc # 2010-18223
This is comment on Proposed Rule
Distribution of Source Material to Exempt Persons and to General Licensees and Revision of General License and Exemptions
View Comment
Related Comments
Public Submission Posted: 12/07/2010 ID: NRC-2009-0084-0006
Nov 23,2010 11:59 PM ET