[ RadSafe ] Radioactive Material, Commerce, and DOT Regulations

[Scott Davidson]

With all respect due to any other commenter, would the source in question be
classified as radioactive under DOT if it did not pass both a concentration
*and* quantity (for the consignment) test under 49 CFR 173.436?

B. Scott Davidson, CHP, CSP


On 5/11/07, edmond0033 <edmond0033 at comcast.net> wrote:
>
> 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!!!"
> >>
> >>
> >>
> >> _______________________________________________
> >> You are currently subscribed to the RadSafe mailing list
> >>
> >> Before posting a message to RadSafe be sure to have read and understood
> > the RadSafe rules. These can be found at:
> > http://radlab.nl/radsafe/radsaferules.html
> >>
> >> For information on how to subscribe or unsubscribe and other settings
> > visit: http://radlab.nl/radsafe/
> >
> > _______________________________________________
> > You are currently subscribed to the RadSafe mailing list
> >
> > Before posting a message to RadSafe be sure to have read and understood
> > the RadSafe rules. These can be found at:
> > http://radlab.nl/radsafe/radsaferules.html
> >
> > For information on how to subscribe or unsubscribe and other settings
> > visit: http://radlab.nl/radsafe/
> >
>
>
> _______________________________________________
> You are currently subscribed to the RadSafe mailing list
>
> Before posting a message to RadSafe be sure to have read and understood
> the RadSafe rules. These can be found at:
> http://radlab.nl/radsafe/radsaferules.html
>
> For information on how to subscribe or unsubscribe and other settings
> visit: http://radlab.nl/radsafe/
>