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

[Dustin G Miller]

Yes...I was speaking only on DOT regulations.  I never said they would apply
to international shipping.

As far as your reasoning that a sealed source being an article, I still
disagree.  You are missing the last 4 words of the definition that say
"...as a component part."    In an electron tube, the RAM performs a
function, along with other components, inside the article.  With a sealed
source, you are shipping radioactive material in a shielded container.  The
lead and other materials do nothing but shield the source.  

Btw - I am not an expert in making sealed sources, but from the accidents I
have read about, most contain a dispersible powder in the sealed capsule.

And, not to be rude, but you may want to talk to your DOT Shipping trainer
regarding this issue as well as what constitutes a DOT class 7 RAM shipment
before you make another shipment.  Fines can be stiff (up to $50k per day)
even for labeling something that does not need to be labeled.  

I know of a guy (no it wasn't me!!) who shipped an empty Hydrogen cylinder
back to the supplier but did not remove the hazard class label from the
original package.  Since the cylinder was empty, it no longer fit the
definition of the hazard class.  The regulatory agency happened to check the
package and as a compliance check contacted his company for training certs.
When they found out the cylinder was actually empty, the regulators told the
president of the company that they could have been fined $50k per day for
transit for improperly labeling the container. 

Just trying to be helpful.

Respectfully,

Dustin 




-----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 2:15 PM
To: radsafe at radlab.nl
Subject: [ RadSafe ] RE: UN2910 Labeling for EXEMPT Calibration
Sources-YesorNo

Dustin:

>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.

How is a sealed source (or calibration standard) different from an 
electronic tube provided as an example in the 49CFR173.403 definition?  An 
electron tube by itself is not an instrument, it is an article.  A sealed 
source falls under the category of "... or similar instrument or article 
having Class 7 (radioactive) material in
gaseous or non-dispersible solid form as a component part."

Again, it is assumed that Mr. McCarn might ship the source from within or 
to the DOT jurisdiction of the US - 49CFR might not apply to his potential 
source shipment.

Henry





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