[ RadSafe ] Radioactive Material, Commerce, and DOT Regulations

[Don Jordan]

Yes,

The DoT regulations apply to "carriage on a public highway", even if you are
carrying the check source in your pocket.

Most of your examples would usually qualify as Limited Quantities and would
be exempt from most packaging and documentation rule.  Some of your examples
would be consumer goods and would be exempt from all the hazmat regulations.

Moisture density gauge owners and radiographers also require specific
radioactive materials licenses.  Interestingly,  radioagraphers have their
own set of NRC transport regulations.  They typically transport Type B
quantities, but do not have to have a 10 CFR Part 71 QA program.

In a prior existence, however, I found one way to make all the DOT hazmat
regs. go away.  The key is public access.  If you can prevent public access
during transport, you may be free from the rules.  We had to ship a nasty
Type B quantity 2 blocks, but my employer owned all the land & buildings
along the route and also owned a private, sworn police force who could block
streets.  A call to DOT confirmed my reading of one of their more obscure
letters of interpretation that the hazmat reg.s wouldn't apply.  We still
hired a consultant to do the shipping & put it on a truck.  Cost was about
$1500, I think.

  Don Jordan

RAM Services, Inc.
920-686-3889
----- Original Message ----- 
From: "Mercado, Don" <don.mercado at lmco.com>
To: "radsafe" <radsafe at radlab.nl>
Sent: 11 May, 2007 5:05 PM
Subject: [ RadSafe ] Radioactive Material, Commerce, and DOT Regulations


> Happy Friday,
>
>
>
> I have a question about individuals carrying around radioactive material
> in their own or company vehicles. Does *everyone* carrying radioactive
> material on public roadways have to comply with all the DOT regulations?
> I'm thinking about people like the sales person who brought an ECD
> containing Ni-63 with him to install on one of our electron microscopes.
> Or the sales man who carries a check source to demonstrate the survey
> meters he's selling. The guy driving around with the moisture density
> gauge in his van or the source radiography operators? Someone who throws
> a generally licensed exit sign or a radium dial clock in their trunk.
>
>
>
> Are these people breaking the law? Looking at the definition of
> "commerce", I think they are.
>
>
>
> Comments please. Thanks in advance. Have a great weekend.
>
>
>
>
>
> 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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