[ RadSafe ] Reuse of Spec Packaging

[Robert D Gallagher]

If you look at 173.475, before each shipmentof any Class 7 package, the
offeror must ensure by examination or appropriate tests, that:

The packaging is proper for the contents to be shipped,

The packaging is in unimpaired physical condition, except for superficial
marks,

Each closure is properly installed , secured, and free of defects,

If fissile proper moderator is present,

Each instruction for proper filling , closing, and preparation has been
followed,

etc, etc, etc

It would appear from your description that for the package described, the
inner closure is not present, it is not in unimpaired condition, and you
probably dont have a copy of the packaging instructions.

As a result, I would not believe that you could legally put the package back
into transport.

If the original shipper had tested and shipped the material in a removable
top can such as a paint can and that can was secondarily packaged in a 5
gallon pail with a bolted lock ring, you could open the outer can, open the
inner can, inspect the source, and repackage. In this case, if you obtained
a copy of the packaging instructions and fllowed them during preparation for
reshipment, your reuse of the packaging would be totally acceptable.


Bob Gallagher
NSSI
713 641-0391

-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl]On
Behalf Of Mercado, Don
Sent: Monday, July 23, 2007 4:32 PM
To: radsafe
Subject: [ RadSafe ] Reuse of Spec Packaging


Happy Monday all,



I've been told that the DOT regulations permit you to re-use another
company's spec packaging as long as it is in good shape. I've looked all
over for that citation but can't find it. Does anyone know the chapter
and verse, or even if it exists?



Here is my situation: I receive sources in 7A Type A packaging from a
vendor. I leak test, open the package, do my thing with paperwork, add
an internal tracking number, yadda yadda. Now I have to forward it on to
the end user in another city. Can I legally put the source back into the
original container, seal it with a tape that is different than the
vendor's, and ship it without having package testing documentation from
the packaging supplier? The internal container has been compromised
because the source comes sealed in a pop-top can. The pop-top is gone.



Thank you in advance for your help.



Donald P. Mercado

Radiation Safety Officer

Explosives Safety Officer

Lockheed Martin Space Systems Company

O/9K-2S, B/157

1111 Lockheed Martin Way

Sunnyvale, CA 94089

Ph. (408) 742-0759

Fx. (408) 756-0504

Don.Mercado at lmco.com



"Life is not a journey to the grave with the intention of arriving
safely in a pretty and well preserved body, but rather to skid in
broadside, thoroughly used up, totally worn out, and loudly proclaiming
-- WOW!!! -- What a Ride!!!"



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