ML20023E082

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Responds to 830518 Request for Interpretation of 10CFR21 Re Supplier of commercial-grade Product.While Manufacturer/ Supplier Not Subj to Part 21 Regulations,Manufacturer/ Supplier Must Rept Known Defects or Failures
ML20023E082
Person / Time
Issue date: 06/02/1983
From: Potapovs U
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Hengeli S
EMVSPTM
Shared Package
ML20023E083 List:
References
NUDOCS 8306070186
Download: ML20023E082 (2)


Text

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'm 0 21983 Mr. Steve Hengeli Quality Assurance Manager Special-T-Metals Co., Inc.

P. O. Box 14810 Lenexa, Kansas 66215

Dear Mr. Hengeli:

This is in response to your letter dated May 18, 1983, in which you requested an interpretation of 10 CFR 21 as it pertains to a supplier of a commercial grade item.

A " commercial grade item" is defined in 10 CFR 21.3(a-1) as an item that is:

"(1) not subject to design or specification requirements that are unique to facilities or activities licensed pursuant to Parts 30, 40, 50, 60, 70, 71, or 72 of this chapter [ Chapter 1 of 10 CFR] and (2) used in applications other than facilities or activities licensed pursuant to Parts 30, 40, 50, 60, 70, 71, or 72 of this chapter and (3) to be ordered from the manufacturer / supplier on the basis of specifications set.forth in the manufacturer's published product description (for example, a catalog)."

A commercial grade item is not a part of a basic component, as that term is defined in 10 CFR 21.3(a), until after dedication; 1.e., after receipt when the item is designated for use as a basic component.

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It is provided in 10 CFR 21.7 that suppliers of commercial grade items are exempt from the provisions of Part 21 to the extent that they supply l

commercial grade items. While an individual or a manufacturer / supplier of a

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l Special-T-Metals Co., Inc. commercial grade item is not subject to the regulations in Part 21, nothing in i

those regulations should be deemed to preclude such an individual or manu-facturer/ supplier from reporting to the Commission a known defect or failure l

to comply.

Indeed, we encourage such cooperation in the interest of greater public health and safety.

If you should have any additional questions, please let me know.

Sincerely,

'orwent s:cnod bn U. POTAPOYS" Uldis Potapovs, Chief Vendor Program Branch

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J. Collins R. Bangart U. Potapovs DMB-IE:19 w/ enc 1.

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