Aaron has considerable experience with regulatory issues associated with radioactive materials, including requirements under the rules of the U.S. Nuclear Regulatory Commission (NRC), NRC Agreement States, and the U.S. Department of Transportation (DOT). Examples of his work in this area are provided below. Outcomes in individual matters may vary significantly, depending on the facts involved and other factors.

NRC Licensing & Exemptions

Aaron has helped numerous clients with NRC (and Agreement State) licensing or license exemption issues for manufacture, import, distribution, use, or disposal of various products with radioactive components. Examples include the following:

• For a trade association for manufacturers and distributors of products that may contain radioactive “source materials” (e.g., thorium) or “by-products” (e.g., tritium or krypton), he prepared a detailed overview of NRC licensing requirements and exemptions that might apply to manufacturing, possession, distribution, import, and export. 
• For a manufacturer and distributor of products with radioactive components, he performed a top-to-bottom review of the company’s licenses from NRC and Agreement States for each step of the supply chain and production process, including import of components, incorporation of the components into products at several facilities, domestic distribution of the finished products, and exports of the products. This effort uncovered the need for both new and modified licenses for certain activities.
• For a company with an online marketplace for sale of consumer products by third parties, he developed recommendations for ensuring that NRC-regulated products were not being made available on the website or were properly covered by necessary licenses. 

Transportation

Aaron has assisted several clients with DOT and international requirements for the transport of materials or products containing radioactive isotopes. Building on his technical background, he commonly starts these efforts with an evaluation of whether the materials meet the relevant definition of radioactive materials in the first instance, and, if so, which category of radioactive materials applies (e.g., excepted quantities or articles, low specific activity (LSA) material, surface contaminated objects (SCO), or Type A or B packages). He then addresses, as needed, the detailed requirements for the relevant category, such as packaging, marking, labeling, placarding, shipping papers, emergency response information, security planning, registration, and personnel training.

For one manufacturer of industrial products containing varying amounts of different radioisotopes (and, in some cases, other hazardous components), he has developed practical guides for shipping packages with different combinations of the products. He has also prepared a first-of-its-type application for a DOT special permit (still pending) that would allow the company to ship the products as non-regulated materials, subject to certain conditions developed using highly technical radiological risk modeling.