Status of Entire 10 CFR 851 as a New Safety and Health Standard that Qualifies for a Temporary Variance

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September 23, 2008

Response to April 4, 2008 letter from Joseph N. Herndon, Director, Environment, Safety, Health and Quality, UT-Battelle, LLC, Oak Ridge National Laboratory, requesting for an interpretive ruling pursuant to 10 CFR Section 851.7 as to "whether health and safety standards, including reference standards and codes, that existed prior to the promulgation of 10 CFR [Part] 851 constitute new safety and health standards for purposes of considering whether a temporary variance request may be granted under Section 851.31?"