Does 10 CFR 31.5 currently impose any limits on the amount of radioactive material in a GLD?
No, but such limits are imposed by Title 10, Section 32.51, of the Code of Federal Regulations (10 CFR 32.51), “Byproduct material contained in devices for use under ยง31.5; requirements for license to manufacture or initially transfer.” Specifically, 10 CFR 32.51 includes safety criteria to limit the potential doses that are likely to result from the use of GLDs, or from accidents involving such devices. In particular, one criterion is that a GLD must be designed and manufactured with inherent radiation safety features so that they may be safely used by someone with no special radiation training or experience.