Disposal Requirements for Specific and Exempt Licensed Smoke Detectors
See the letter from J. W. N. Hickey to D. L. Tremblay (Simplex Time Recorder Company) dated October 5, 1981.
Imported smoke detectors possessed under a specific license must be returned to the manufacturer. A licensee who possesses detectors distributed as exempt items is exempt from regulatory requirements regarding the smoke detectors, and they may be disposed of as ordinary trash.
Your letter to General Counsel dated September 8, 1981 has been referred to the Division of Fuel Cycle and Material Safety. In our telephone conversion, you explained that your company possesses two types of smoke detectors: those imported, possessed, and distributed in accordance with NRC License Nos. 20-17584-01 and 20-17584-02E, and those obtained from an American manufacturer as exempt units.
We agreed that the imported detectors must be returned to the manufacturer in accordance with your licenses, and that your letter concerns the domestic units. To the extent that you possess domestic smoke detectors distributed as exempt units, you are exempt from any regulatory requirements. Therefore, you may dispose of these units as ordinary trash.
Regulatory references: 10 CFR 30.20, 10 CFR 32.26
Subject codes: 3.3, 9.0
Applicability: Byproduct material