# tritium question: T25 vs T100



## stockae92

which are the models with T<100? i thought swiss has regulation to limit tritium use to be under 25? (i could be wrong on this)

some ball models with tritium numbers and they are still T<25? (seems like the tritium numbers use a lot more tritium tubes than say a traser, which is T<25)


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## obie

In regards to the level of tritium, it is an import issue that/can varies from country to country. In the US, the NRC believed that only watches containing 25 millicuries or under of tritium were allowed for import. Dan, one of the V.P.'s of Ball Watch USA looked into the regulations and believed that the NRC was misreading their own regulations, and sucessfully argued that Ball Watch USA be allowed to import watches with as much as 100 millicuries of tritium. This came about because Ball Watch USA was accidentely shipped several 100 millicuries watches when the rules at that time stated 25 and under.


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## Frontierman63

obie said:


> In regards to the level of tritium, it is an import issue that/can varies from country to country. In the US, the NRC believed that only watches containing 25 millicuries or under of tritium were allowed for import. Dan, one of the V.P.'s of Ball Watch USA looked into the regulations and believed that the NRC was misreading their own regulations, and sucessfully argued that Ball Watch USA be allowed to import watches with as much as 100 millicuries of tritium. This came about because Ball Watch USA was accidentely shipped several 100 millicuries watches when the rules at that time stated 25 and under.


And correct me if i'm wrong somone,but Ball is the Only watch mfr allowed to import T100's in the USA :-!


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## Weiting

I saw the following article that from somewhere I forgot.

--------------------------------------------------------
Swiss T 25 (T Swiss made T)
(In French: Swiss T 25 (T Swiss made))
So that watches (and timekeeping devices in general) can be read in the dark, the numerals, hour markers and hands must be coated with a luminescent substance. As a general rule, this emission of light is either photoluminescent (using energy absorbed from a light source) or radioluminescent (using the radioactive property of the coating substance).
Radioluminescence is generally reserved for watches intended for professional use, such as military watches or diving watches, and is strictly regulated by ISO 3157 which allows only two types of radionuclides: tritium (3H) and promethium (147 Pm). Both these radionuclides emit very low-energy radiation.

ISO 3157 provides for optional marking of timekeeping devices that emit less than a certain value. This marking can be shown on the dial as follows:
tritium-activated deposits: T
promethium-activated deposits: Pm

In contrast, devices that emit above this value must be marked as follows:
tritium-activated deposits: T 25
promethium-activated deposits: Pm 0.5

"T Swiss made T" means that the watch is Swiss and contains a certain quantity of tritium that emits less than 227 MBq (7.5 mCi). "Swiss T<25" means that the watch is Swiss and contains a certain quantity of tritium that emits less than 925 MBq (25 mCi). Most Swiss watches use photoluminescent light emission, sometimes indicated by the optional marking, "L Swiss Made L".

-------------------------------------------------

So according to the above description, the conclusion is I think T100 is better than T25.


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## pdoherty

Frontierman63 said:


> And correct me if i'm wrong somone,but Ball is the Only watch mfr allowed to import T100's in the USA :-!


Can someone explain the logic behind Ball being the only ones who can import T100, because it makes no sense to me. They simpy reakized the regs were being enforced incorrectly; why should that grant them a monopoly on it?


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## lvt

pdoherty said:


> Can someone explain the logic behind Ball being the only ones who can import T100, because it makes no sense to me. They simpy reakized the regs were being enforced incorrectly; why should that grant them a monopoly on it?


It's very simple, Ball is the most American of all watch manufacturers |>


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## samanator

pdoherty said:


> Can someone explain the logic behind Ball being the only ones who can import T100, because it makes no sense to me. They simpy reakized the regs were being enforced incorrectly; why should that grant them a monopoly on it?


Please read Jeff's comments and your interpretation really is over simplifying the amount of work required to get a legal exception to the regulations (I know, I do this as my day job):

https://www.watchuseek.com/showthread.php?p=3129137#post3129137

If you spent your companies time and resources to get a license that took a year to get would you just give it away to others? Please note there is nothing stopping other companies from doing the same thing. So the better question would be to direct this to the other companies as to why they are not doing it? It's not a monopoly if others consciously choose not to compete.


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## jhess

Samanator nailed it.

no monopoly. We just did the due diligence.

It was quite a hassle and very time consuming and expensive. But My VP Dan Hall spearheaded this deal and against my better judgement (I NEVER want to mess with the Feds!) proved to them that they were misinterpreting their owns laws.

So we were the first, due to Dan's egg-headed determination. (And believe me the NRC dudes are VERY intimidating no-nonsense serious and scarry fellows)...but certainly not the last. Many companies are already saying they have applied for the license.

So I guess (again due to Dan's bullheadedness, LOL) our little company is either a "leader" or at least a "Unique Early Adapter"), but have no monopoly. 

Jeff

That said, we received in the mail today a book of "proposed changes" to the lume laws for watches from the NRC. All of tried to read it yesterday and all of us (even Dan) either got a headache or nodded out. (the combo of government speak and technical data was daunting). But we plan on attacking it today again.


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## pdoherty

samanator said:


> Please read Jeff's comments and your interpretation really is over simplifying the amount of work required to get a legal exception to the regulations (I know, I do this as my day job):
> 
> https://www.watchuseek.com/showthread.php?p=3129137#post3129137
> 
> If you spent your companies time and resources to get a license that took a year to get would you just give it away to others? Please note there is nothing stopping other companies from doing the same thing. So the better question would be to direct this to the other companies as to why they are not doing it? It's not a monopoly if others consciously choose not to compete.


What I'm not understanding is why there's anything that needs to be done. You uncovered a mistake in the enforcement of federal regulations regarding the importation of tritium; now that this has been discovered (and the feds are onboard, recognizing their mistake) why must any other company do anything to toe the line with regard to regulations now that it's understood the regulations are T100 or less?


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## pdoherty

jhess said:


> That said, we received in the mail today a book of "proposed changes" to the lume laws for watches from the NRC. All of tried to read it yesterday and all of us (even Dan) either got a headache or nodded out. (the combo of government speak and technical data was daunting). But we plan on attacking it today again.


What do the changes appear to convey? An increase in restrictions? An easing of restrictions further? Or neither?


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## samanator

pdoherty said:


> What I'm not understanding is why there's anything that needs to be done. You uncovered a mistake in the enforcement of federal regulations regarding the importation of tritium; now that this has been discovered (and the feds are onboard, recognizing their mistake) why must any other company do anything to toe the line with regard to regulations now that it's understood the regulations are T100 or less?


Again Jeff is trying to keep this to simple forum terms. While it may have been a misapplication of the law it still required a license to take advantage of it. Very common with almost any licensed, regulated commodity by the US government. Ball did the work and got the license. The others can do the same.

My suggestion should you require more information is to go to the NRC site and read through all the material there on Tritium regulations and why they were put in place.


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## roberev

jhess said:


> That said, we received in the mail today a book of "proposed changes" to the lume laws for watches from the NRC. All of tried to read it yesterday and all of us (even Dan) either got a headache or nodded out. (the combo of government speak and technical data was daunting). But we plan on attacking it today again.


Those darned lawyers. :-d

I'm sitting here reading 10 C.F.R. § 32 Subpart A and 10 C.F.R. 30.70 Schedule A for fun right now. o|

So . . . the exempt amount is 5 x 10-6 microcuries (or 5 x 10-9 millicuries (0.000000005 millicuries)) . . . and anything over 1000 microcuries (1 millicurie) requires labeling. I'm still digging for the 100 millicurie limit on an exemption license. The whole "Table of Organ Doses" (10 C.F.R. § 32.24) and converting mCi ingestion to rem dosage/exposure has my head spinning!

Perhaps Florida or New York is an "Agreement State" with higher limits that opens the door to greater mCi levels. :think:

My hat's off to Dan for wading through all this . . . and understanding it!

Rob


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## jhess

If Rob gets a headache, just imagine the size of the headache us "non-lawyers" get when trying to read this stuff.

Jeff, no wonder they misinterpreted their own rules....


Tough to figure this stuff out!


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## scottw44

Great work Michael, Jeff, and Rob. I have long been impressed with the work Dan completed, the due diligence, follow-up, and subsequent licensing.

Like Michael said, more than most co's would go through...except if your a company who is the leader in automatic GTLS timepieces!!! Brilliant!


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## bg002h

pdoherty said:


> Can someone explain the logic behind Ball being the only ones who can import T100, because it makes no sense to me. They simpy reakized the regs were being enforced incorrectly; why should that grant them a monopoly on it?


As a resident physician in radiology having to undergo licensing with the Nuclear Regulatory Commission, I can tell you that obtaining a license from the NRC implies a very specific detailing of what you intend to do with radioactive substances...you write down for them absolutely everything you intend to do and are permitted to do only that...you can not, for example, just follow guidelines for what is permitted if it's not specifically part of your license. Neither Ball nor any other company can sell T100 watches when they have a T25 license...each company needs to apply for their own T100 license and give a detailed plan on how they intend to use that level of radiation....if you, for whatever reason, obtain a "T10" license, you can't use T25, even if your competitor is doing so across the street...you need a new license.


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## jhess

My head hurts.

But I think this freaking long government speak document 10 C.F.R.30 to 32 Subpart A and 10 C.F.R. 30.70 Schedule A has a very salient point regarding "some" (not specified which though arrrrrrggh) radioactive materials in "certain products".

I think "Some products" will be less regulated.

But then again, I may have dreamed that. Since I fell asleep several times while trying to read this.

More later.
Jeff

Page 36217 Part B is interesting, Rob.


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## roberev

jhess said:


> My head hurts.
> * * *
> Page 36217 Part B is interesting, Rob.


I have but with a cursorary eye O'erglanced the articles [sorry Shakespeare], and agree that it's very interesting!

I'm hung up on the paragraph in Part B that says that the proposed exemption will include "the same list of purposes as are covered under the general license of 10 CFR 31.5, with the _exception_ of that of producing light. The existing class exemption for self luminous products is considered adequate. . . ." :think:

It's late. Perhaps I'll tackle it again tomorrow. Reading the Federal Register is better than Ambien when it comes to inducing sleep. :-d

Rob


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## zekio

jhess said:


> Samanator nailed it.
> 
> no monopoly. We just did the due diligence.
> 
> It was quite a hassle and very time consuming and expensive. But My VP Dan Hall spearheaded this deal and against my better judgement (I NEVER want to mess with the Feds!) proved to them that they were misinterpreting their owns laws.
> 
> So we were the first, due to Dan's egg-headed determination. (And believe me the NRC dudes are VERY intimidating no-nonsense serious and scarry fellows)...but certainly not the last. Many companies are already saying they have applied for the license.
> 
> So I guess (again due to Dan's bullheadedness, LOL) our little company is either a "leader" or at least a "Unique Early Adapter"), but have no monopoly.
> 
> Jeff
> 
> That said, we received in the mail today a book of "proposed changes" to the lume laws for watches from the NRC. All of tried to read it yesterday and all of us (even Dan) either got a headache or nodded out. (the combo of government speak and technical data was daunting). But we plan on attacking it today again.


thanks for the simple explanation. i was wondering for quite a while why no other watch companies were using tritium. at least for SOME of their more toolish models


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