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
>
>http://www.faa.gov/avr/AFS/FARS/far-108.txt
>
>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 <[EMAIL PROTECTED]> 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
>Photos: http://www.spirer.com
>One People: http://www.onepeople.com/

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