[ RadSafe ] Radioactive Material, Commerce, and DOT Regulations

[edmond0033]

Depends upon what your Agreement State or NRC License allows you to do (if 
you have one)??

Ed Baratta

edmond0033 at comcast.net
----- Original Message ----- 
From: "Don Jordan" <DonJordan at ramservicesinc.com>
To: "radsafe" <radsafe at radlab.nl>
Sent: Friday, May 11, 2007 8:41 PM
Subject: Re: [ RadSafe ] Radioactive Material, Commerce, and DOT Regulations


> 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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