[ RadSafe ] RE: UN2910 Labeling for EXEMPT Calibration Sources -YesorNo

[Dustin G Miller]

You may have an instrument or article with a sealed source in it that may be
shipped under UN2911, but a sealed source (or calibration standard) by
itself is not an instrument or article.

For the definition of "Radioactive Instrument or Article" see 49CFR173.403.
I have also included some definitions that help with our shipping question
(for domestic ground shipments).  These definitions follow one right after
the other in 49CFR173.403.

--------------------------------------------------------------------------
Radioactive contents = means a Class 7 (radioactive) material, together with
any contaminated or activated solids, liquids and gases within the
packaging. 

Radioactive instrument or article = means any manufactured instrument or
article such as an instrument, clock, electronic tube or apparatus, or
similar instrument or article having Class 7 (radioactive) material in
gaseous or non-dispersible solid form as a component part. 

Radioactive material = means any material containing radionuclides where
both the activity concentration and the total activity in the consignment
exceed the values specified in the table in § 173.436 or values derived
according to the instructions in § 173.433 . 

Special form Class 7 (radioactive) material = means either an indispersible
solid radioactive material or a sealed capsule containing radioactive
material which satisfies the following conditions: 

(1) It is either a single solid piece or a sealed capsule containing
radioactive material that can be opened only by destroying the capsule; 

(2) The piece or capsule has at least one dimension not less than 5 mm (0.2
in); and 

(3) It satisfies the test requirements of § 173.469 . Special form
encapsulations designed in accordance with the requirements of § 173.389(g)
in effect on June 30, 1983 (see 49 CFR part 173 , revised as of October 1,
1982), and constructed prior to July 1, 1985 and special form encapsulations
designed in accordance with the requirements of § 173.403 in effect on March
31, 1996 (see 49 CFR part 173 , revised as of October 1, 1995), and
constructed prior to April 1, 1997, may continue to be used. Any other
special form encapsulation must meet the requirements of this paragraph (3).
----------------------------------------------------------------------------

Dustin G. Miller



-----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 1:38 PM
To: radsafe at radlab.nl
Subject: [ RadSafe ] RE: UN2910 Labeling for EXEMPT Calibration Sources
-YesorNo

Simon:

>You should be careful shipping your sealed sources as "instruments and 
Articles" as it requires a level of rigor that many sealed sources don't 
meet to qualify as an "instrument" under DOT.

What is your basis for this statement?  What "level of rigor" does DOT 
require for a sealed source to "qualify as an instrument" or article under 
DOT?  I have not seen DOT define what constitutes an instrument or article 
in its regulations.

The DOT statement is"... instruments OR articles" not "... instruments AND 
articles."

Also, Mr. McCarn did not state the origin or destination of the sources he 
inquired about and might be shipping.  Why are you assuming that he is 
shipping to or from within the borders of the US?

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


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