As I read it, this section says only that the "Administrator" which means the
FAA administrator (and ONLY the FAA Administrator) can, if (s)he finds it
necessary revise any of the rules by issuing a notification to certificate
holders (i.e. the companies handling security screening - airlines actually at
present) that a rule is to be waived. Since the Administrator has issued no
such notice regarding the hand checking film provision, the rule does apply
WITHOUT exception.
The rule is as follows.
(e) No certificate holder may use an X-ray system to inspect carry-on or
checked articles unless a sign is posted in a conspicuous place at the
screening station and on the X-ray system which notifies passengers that such
items are being inspected by an X-ray and advises them to remove all X-ray,
scientific, and high-speed film from carry-on and checked articles before
inspection. This sign shall also advise passengers that they may request that
an inspection be made of their photographic equipment and film packages without
exposure to an X-ray system. If the X-ray system exposes any carry-on or
checked articles to more than 1 milliroentgen during the inspection, the
certificate holder shall post a sign which advises passengers to remove film of
all kinds from their articles before inspection. If requested by passengers,
their photographic equipment and film packages shall be inspected without
exposure to an X-ray system.
Note the important word in this section is "shall". Just as this REQUIRES the
posting of the requisite sign it REQUIRES the inspection of film "without
exposure to an X-ray system".
Having said that the rule is absolute (unless the FAA Administrator formally
change it), the uneven application of the rule is just one symptom how inept
and unprofessional our security screening has been and still is. There is of
course some hope that the friendly federal employees soon to appear at your
neighborhood airport security screen will be better trained and actually
understand and know the rules. However, I for one will not hold my breath.
My solution - use 50 iso film (underwater we almost always use strobe light
anyway), travel with the film in double thickness lead lined bags, ask for hand
check but just it through the X ray machine if the hand check is refused too
vigorously. Note that although the intensity of some carry on baggage X-ray
machines CAN be cranked up some, the rules set a relatively low maximum
intensity for health safety reasons and the equipment manufacturers are not
about to spend more money to produce more powerful equipment that can be
cranked up to exceed this limit (product liability laws actually do some good
sometimes). Caution, some CHECKED baggage scanners can and do irradiate at
much higher intensities and film should NEVER be sent in checked bags (had to
say that or someone would miss that I was only talking about carry on bag
scanners).
I usually carry 100-200 rolls of film and often travel through many airports
(and multiple security screens) getting to the remote destinations and then
back home. In some instances the film has gone through as many as 15-18 X-ray
machines before we get it home and process it and we have NEVER (yet - fingers
crossed) seen any adverse effects.
What I have said above applies to US airlines and airports. Other countries
have different rules - usually giving the screener more discretion and power.
While there has been much focus on the US regulations, it seems to me that it
is more important that the ICAO and other international regulations be
consistent and evenly applied by all nations. Anyone care to address how this
might be approached?
At 10:26 AM 11/25/2001 -0800, you wrote:
>FAR 108.25
>
>
>
>Note that (b)(3) says that rules can be suspended fairly arbitrarily, although
>it is couched in language that makes that a bit obscure, as it states
>everything in terms of certificate holders rather than the public. However,
>this is the way in which the entire regulation is written.
>
>At 08:56 AM 11/25/01, Robert Meier wrote:
>
>>--- Jeff Spirer <jeff@spirer.com> wrote:
>>> Having read the entire FAA regulations, I will point out that the
>>> regulations have ALWAYS allowed for immediate suspension of the film
>>> check
>>> provision. The right to suspend is not in any way connected to
>>> 9/11.
>>
>>Jeff,
>>
>>can you provide a link to the text that allows the suspension of hand
>>checking film. Just for my personal interest.
>>
>>Robert
>>
>>__________________________________________________
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>
>Jeff Spirer
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