Public comments for: Operation of Body Scanners in Correctional Facilities (New Chapter 33 to Title 24 of the RCNY)

Comments

Comment:
Dear Sir/Madam, Regarding Chapter 33 of Title 24 of the Rules of the City of New York, pertaining to the use of body imaging scanning equipment by the New York City, Department of Corrections, Smiths Detection supports the legislation as approved by the State of New York and the City of New York, with the following comments: Proposed Section 33-04(d) page 7 The proposed device for testing image quality is not a commercially available product. Smiths Detection proposes that image quality be measured using a standard test piece that is derived from the TSA measurement methods (see picture on page 2). This is a wire resolution and step wedge card mounted on a body scanner specific stand that provides the essential monitoring of imaging performance for the transmission X-Ray system. Proposed section 33-05(a) The exposure limits of the body scanners are currently set to match the American National Standards Institute (ANSI). The proposed modification in section 33-05(a) reduces this limit by 50%. This reduction seems unnecessary, as the standards are already set below the amount permitted by the general public. In summary, the use of body scanners in the United States has proven to significantly reduce contraband and threat items in correctional institutions. This new legislation is a significant step forward by the City of New York to increase the security and safety at correctional facilities. Thank you for the consideration. Yours sincerely, Jamie Edgar Director, Homeland Security Systems Smiths Detection, Inc. 212-234-4090
Supporting Document:
Agency: DOHMH