[ RadSafe ] Re: UN2910 Labeling for EXEMPT Calibration Sources - Yes or No

Wed Jul 22 10:41:59 CDT 2009

All,
Sealed Sources are not instruments or articles- UN2911. An instrument or
article is something that can not function with out it’s radioactive
component, such as a smoke detector or EXIT sign. 
Sources, sealed or otherwise, are radioactive material. If the activity
stays under the amounts listed in 49 CFR 173.425. If the activity is under
what is listed in this table then the requirements of 49 CFR 173.424 must be
met. One of those requirements is that the radiation level at any point on
the external surface of the package does not exceed 0.5 mrem/h.
The Exception of 49 CFR 173.421 for limited quantity, states that limited
quantity is excepted form specification packaging, labeling, marking (except
for the UN identification number marking requirement described in
173.422(a), and if not a hazardous substance or hazardous waste, shipping
papers,...
So, you do not have to label the package (White I), you do not have to mark
the package with the Proper Shipping Name, you do not have to have a
shipping paper unless it is a hazardous substance or hazardous waste.
The only marking the package needs is UN2910. This is a marking not a label
requirement.
It sounds like the company that is accepting the material does not want a
package that has a White I label, and under the exception of 49 CFR 173.421
it would not be required if it meets the limits for Limited Quantity.
Jonetta

-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On Behalf
Of roseb at gdls.com
Sent: Wednesday, July 22, 2009 8:55 AM
To: radsafe at radlab.nl
Subject: [ RadSafe ] Re: UN2910 Labeling for EXEMPT Calibration Sources -
Yes or No

Dan:

>As I understand it, exempt calibration sources are covered under the 
UN2910 labeling guidelines; is this correct? Or are they exempt from 
labeling as well?

If the sources are sealed sources (i.e. button, electroplated, etc.) and 
are normal form, they should be shipped UN 2911.  If the sources are in 
liquid, powder, gas, or other readily dispersible form, they should be 
shipped as UN2910.

Sealed sources can be shipped as "Radioactive material, excepted package - 
instruments or articles - UN2911".  Dispersible sources can be shipped as 
"Radioactive material, excepted package - limited quantity of material - 
UN2910". The packages must meet all of the applicable quantity (A1 & A2) 
limits, package dose rate and surface contamination limits, marking, and 
additional labelling requirements of IATA, IMDG, USDOT, USPS, other 
applicable national or international dangerous goods / hazardous materials 
transportation regulations, and the dangerous goods / hazardous materials 
trade / tariff requirements of the transporter (i.e. DHL, FedEx, UPS, 
etc.) depending on the mode of shipment (could be multiple modes such as 
air and highway) or transport and where the packages are being shipped.

>So? being exempt, do they require labeling?

The materials at minimum require marking in order to declare them as 
dangerous goods or hazardous materials.  An exemption of a source due to 
its quantity under one set of regulations (i.e. 10CFR) does not exempt the 
same source from the requirements of other regulations and rules(i.e. 
IATA, IMDG, USDOT, USPS, DHL, FedEx, UPS, etc.)

Also, as Bill Lipton stated, the various transportation regulations 
require hazardous materials employees to be trained in accordance with 
those regulations prior to their performing a transportation function 
(i.e. packaging, marking, and labeling packages, preparing shipping 
papers, declaring packages, loading / unloading packages, placarding, 
etc.)  If you do not have the requisite training in transportation of 
dangerous goods / hazardous materials, you should obtain the assistance of 
or refer the shipment of the sources to a person who has the appropriate 
competency in this area.

Henry

Boyd H. Rose, CM, CIH, CHMM
Sr. Safety and Environmental Engineering Specialist
Corporate Radiation Safety Officer
General Dynamics Land Systems
38500 Mound Road
Mail Zone 436-10-75
Sterling Heights , MI 48310-3269
Tel: 586 825 4503
Fax: 586 825 4015
E-mail: roseb at gdls.com

Dan W McCarn <hotgreenchile at gmail.com> 
Sent by: radsafe-bounces at radlab.nl
07/22/2009 09:49 AM

To
<radsafe at radlab.nl>
cc
sales at spectrumtechniques.com
Subject
[ RadSafe ] UN2910 Labeling for EXEMPT Calibration Sources - Yes or     No

Dear Group:

As I understand it, exempt calibration sources are covered under the 
UN2910
labeling guidelines; is this correct? Or are they exempt from labeling as
well? 

I was just informed that one shipping company does not handle any material
labeled as UN2910.

The sources are labeled on the Spectrum Techniques invoice as CALIBRATION
STANDARDS. 

The activities are as follows:

1.0 uCi Ba-133 ..

1.0 uCi Cd-109 ..

1.0 uCi Co-57 ..

0.1 uCi Cs-137 .. (note that this is the new exempt standard for Cs-137)

1.0 uCi Mn-54 ..

1.0 uCi Na-22 ..

1.0 uCi Co-60 ..

1.0 uCi Zn-65 ..

So? being exempt, do they require labeling?

Dan ii

--
Dan W McCarn, Geologist
8, Le Buisson Sainte Anne
78860 Saint-Nom-la-Bretèche 
+33.(0).1.74.09.03.09 (Land Line) - France) 
+33.(0).6.47.86.05.25 (Mobile - France) 
+1-505-240-6872 (Skype - New Mexico) 
+353 (0) 76 602 6397  (Skype - Ireland)
 <mailto:HotGreenChile at gmail.com> HotGreenChile at gmail.com (Private email)

_______________________________________________
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/

This is an e-mail from General Dynamics Land Systems. It is for the intended
recipient only and may contain confidential and privileged information.  No
one else may read, print, store, copy, forward or act in reliance on it or
its attachments.  If you are not the intended recipient, please return this
message to the sender and delete the message and any attachments from your
computer. Your cooperation is appreciated.

_______________________________________________
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/