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

[Dan W McCarn]

Dear Group:

Wow!  I'm glad that I posted the question! I automatically labeled the
calibration sources as UN2910 from the USA to France last fall assuming that
was the most "correct" way of labeling. I also did not consider that the
improper labeling could be equally as onerous.

I did not expect such a outflow of opinions, but as Henry explained, it has
been a learning experience for a number of us, especially me! Thanks to both
Larry Webb and Cary Renquist for their calculations, and Robert Holcomb on
his very clear explanation.
 
There were over 25 postings and several sideboards on this thread and I can
now proceed with the shipment!  Although I've had my radioactive materials /
safety training at the University of New Mexico several years ago, my need
to transport hazardous / radioactive materials is only occasional.

I'll be sure to keep the calculations, regulations and explanatory letters
in the case with the sources in the event that it is challenged at the
border.

Best!

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)
HotGreenChile at gmail.com (Private email)

-----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 22:45
To: radsafe at radlab.nl
Subject: [ RadSafe ] RE: UN2910 Labeling for EXEMPT Calibration Sources
-YesorNo

Dustin:

>NO, Henry, you are not correct....

To reply in-kind...

YES, Dustin, I know I am not correct: now!  The same goes to Jeff, Bill, 
and everyone else who was kind enough to respond to my posts on this 
subject.

I stand corrected with respect to the individual sources' activity 
concentrations AND activity limits for exempt consignment not meeting the 
definition of Radioactive Material per 49CFR and possibly IATA , IMDG, and 
other regulations (i.e USPS) and tariffs (i.e. DHL, FedEx, UPS, etc.).

As the sources as described and will be offered for shipment/transport do 
not meet the definition of radioactive material and is therefore not 
subject to the US HMR, I concede that the sources do not have to be 
classified Class 7 Radioactive material or marked as either UN2910 or 
UN2911 for transportation in the US.  As I do not have the IATA/IMDG 
regulations in my office at this time (there are several on-site), I am 
not able to confirm that this is the case for international shipment / 
transport.

Also, I appreciate your suggestions in your subsequent post regarding DOT 
training.  However, it is not possible for a trainer to train one on every 
detail of the DOT, IATA, IMDG, and all other regulations.  There comes a 
point where after training, the trainee must carefully and thoroughly 
review the dangerous goods / hazardous materials transportation 
requirements themselves to insure that the packages and consignments he 
offers for shipment / transportation meet all of the applicable 
requirements prior to offering the packages and consignments.  This 
particular discussion and case has alerted me that I need to reset my 
thoroughness and care when preparing or offering radioactive packages for 
shipment / transportation or when offering guidance to others.

Thank you all for the discussion!

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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