[ RadSafe ] RE: Exempt Source Shipment to International Destination
HHedge at GeoSyntec.com
HHedge at GeoSyntec.com
Wed Sep 3 02:01:56 CDT 2008
Dear Dan McCarn,
I agree with Cary Renquist statements on the international shipment whole heartily.
My work in Malaysia has pointed out differences between Malaysia and US regulations and I'm sure you will find some of the same differences for France.
* "NRC Exempt" does not mean Malaysian exempt. I have a CS-137 button source that is NRC Exempt yet I needed a license for possession it in Malaysia.
* Since I ship by air, besides the Atomic Energy Licensing Board (Malaysian NRC) approval, I also need import permits from the Department of Civil Aviation and a Royal Malaysian Customs to bring in sources.
* For air transport Malaysian regulations require the use of the International Civil Aviation Organization (ICAO) documents vice International Air Transport Association (IATA) documents.
* While shipping a radioactive sample from Malaysia to the US for analysis, Malaysian regulators wanted a document from a US Government Agency stating that the receiving laboratory could possess the sample. I was able to work around this by getting a NRC shipping expert to e-mail me a summary of our telephone conversation indicating that it is the licensee's responsibility to ensure that they meet their activity licensing requirements.
If you are using FedEx for your shipment, I would recommend that you contact Roy A. Parker at roy at royparker.org for additional guidance. I believe he is still handing radioactive shipments for FedEx.
Harold Hedge, NRRPT
Radiological Laboratory Manager
GSM Consultancy (M) Sdn. Bhd.
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