[ RadSafe ] Reuse of Spec Packaging

[Roy Parker]

Don,
  1.. Reuse of a radioactive material package is governed by 49 CFR 173.475 in general.
  2.. Pursuant to 49 CFR 173.415 a shipper of a Type A package must maintain on file for at least one year after the latest shipment, and shall provide DOT on request, complete documentation of tests and an engineering evaluation or comparative data showing that the construction methods, packaging design, and materials of construction comply with that specification.  The implications inferred herein are major.
  3.. The above means that a reuser of a Type A package must obtain from the original shipper of that package the complete documentation.
  4.. It may be difficult to obtain complete documentation from the original shipper, because many shippers will not provide this. They may consider it proprietary or a liability issue.
  5.. Many original shippers do not have "complete" documentation.  Complete documentation consists of documentation everything in 49 CFR 173.410, 173.412, 173.465 and 173.466.  Many shipper incorrectly think that the documentation consists only of the tests specified in 49 CFR 173.465 and 173.466.
  6.. The documentation must provide sufficient documentation to prepare shipments exactly as specified in the documentation.  Many times this is not provided or sufficiently provided.  All the components of the package must be exactly as specified in the documentation.  For example: are the limits on the weight specified; is the closure or sealing material properly specified;  is any dunnage or filling material specified; are all the materials use in the construction adequately specified?
Yes, one can reuse a Type A package, but one must be very careful.  For example the inner container you mention below in your email may only be replaced with an identical container.  If another inner container is used, then the documentation must be modified to show that the alternate container is equivalent to the original Type A package design.  When you ship a Type A package you are "certifying" that the package is a Type A package.

Regards,

Roy A. Parker, Ph.D.

----- Original Message ----- 
From: "Mercado, Don" <don.mercado at lmco.com>
To: "radsafe" <radsafe at radlab.nl>
Sent: Monday, July 23, 2007 4:31 PM
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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