[ RadSafe ] UN2910 Labeling for EXEMPT Calibration Sources - YesorNo

Thu Jul 23 10:32:31 CDT 2009

Good Day Everyone,

The US Department of Transportation (USDOT) regulations, due to their sheer size, appear to be deliberately byzantine.  However, if we confine ourselves only to Class 7 (radioactive) materials, then further confine to excepted quantities of Class 7 materials, it is possible to reduce the USDOT regulations to manageable proportions.  

When a tiny fraction of the A1 or A2 activity is considered for shipment under USDOT regulations, some shipments may be excepted from some of the requirements of the USDOT Hazardous Materials Regulations (HMR), and may be shipped in an "excepted package."  The following types of materials may be suitable for applying said exceptions:  1) limited quantity of radioactive material, 2) radioactive instruments or articles, 3) articles manufactured from natural or depleted U or natural Th, and 4) empty packaging.

A "limited quantity of radioactive material" as currently being discussed on RadSafe is a quantity of radioactive material that does not exceed the material's package limits as specified in 49 CFR 173.425, AND conforms to the requirements specified in 49 CFR 173.421.

"Radioactive instruments or articles" are manufactured items such as instruments, clocks, electronic tubes, gauges, smoke detectors, electronic apparatus, or similar devices having radioactive material in gaseous or non-dispersible solid form as a component part.  Consideration is given for the additional protection provided by the structure of the instrument or article, and radioactive materials incorporated into instruments or articles are considered excepted quantities if they do not exceed the limits in 173.425, AND conform to the requirements specified in 173.424.  As seen in the table in 173.425, there are TWO limits:  1) a limit for the item, and 2) a limit for the package.

Excepted packages must meet the following criteria IAW the HMR:

1.  General design requirements of 173.410.
2.  The outside of each package shall be marked with the four digit UN identification number for the material, preceded by the letters UN, as shown in column (4) of the HM Table in 172.101.
3.  Package surfaces must not exceed the non-fixed contamination limits of 173.443(a).
4.  For limited quantities, the outside of the inner packaging or, if there is no inner packaging, the outside of the package itself must bear the marking "Radioactive."
5.  EMPTY labels are required on empty packages.
6.  For instruments or articles, the radiation level at four inches (10.2 cm) from any point on the surface of the UNPACKAGED instrument or article shall not exceed 0.1 mSv/h (10 mrem/h).

It is quite probable that your sources fall under nr. 4 in the list above (limited quantities), but you should look up the tables and do the maths for yourself.  

To recap the references cited, the specific sections of 49 CFR for the various categories of excepted radioactive packages are:

1.  173.421 Excepted packages for limited quantities of Class 7 (radioactive) materials.
2.  173.422 Additional requirements for excepted packages containing Class 7 materials.
3.  173.423 Requirements for multiple hazard limited quantity Class 7 materials.
4.  173.424 Excepted packages for radioactive instruments and articles.
5.  173.425 Table of Activity limits - excepted quantities and articles.
5.  173.426 Excepted packages for articles containing natural U or Th.
6.  173.428 Empty Class 7 materials packaging.

You may access the USDOT regulations at the following link: 

 http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=%2Findex.tpl

-A.J.

A.J. Teachout
Chief, Health Physics Division
Armed Forces Radiobiology Research Institute
8901 Wisconsin Avenue, Bldg. 42
Bethesda, MD  20889-5603

The usual disclaimers apply....

-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On Behalf Of Dan W McCarn
Sent: Wednesday, July 22, 2009 1:58 PM
To: 'Cary Renquist'; radsafe at radlab.nl
Cc: sales at spectrumtechniques.com
Subject: RE: [ RadSafe ] UN2910 Labeling for EXEMPT Calibration Sources - YesorNo

Dear Group:

Cary stated: Based on 49 CFR 173.436; IATA 10.4.2.1; The total for all
sources is ~96% of the exempt consignment limit - "i.e. you do not have
radioactive material..."

>From the training materials from University of Iowa, Slide 31

http://tinyurl.com/IATA-10-4-2-1

supports this view.

The combined activity does not warrant any special handling, as Cary pointed
out.

Cary appears to be correct! If so, I do not need to label anything. 

Is this the consensus?

To be clear to all, I am moving from France back to the USA. These are
calibration sources for a 1024 channel MCA / spectrometer using a 3x3"
NaI(Tl) detector. I included them as a UN2910 labeled package in my
household shipment from the USA to France, no one seemed to question it, and
the bill of lading for the shipment reflected that. They are lead shielded
(about 9 cm length x 6 cm diameter with a 1.25 cm wall thickness) and the
sources themselves are labeled according to USNRC regulation.

As an aside, the activity from the surface of the lead shield (Ludlum Model
19):

0 cm is 150 uR/hr

15 cm is 23 uR/hr

25 cm is 16 uR/hr

50 cm is 11 uR/hr

100cm is 10 uR/hr

Background activity is 9 uR/hr;

Larry Webb at Spectrum Techniques writes:

   All exempt sources must have a label, see attached generic label.

   Must have per USNRC regulation for distribution.

   isotope

   activity

   half-life

   radiation type

   rad symbol

   exempt material statement

   manufacturer

   (we add date of manufacture stamp)

   Yes, we are also have difficulty with carriers.

   Countries are creating new internal rules that may differ from
international accepted rules and regulations.

   Some require prior permission, others delivery to air port only.

   Some of these are published in the IATA regulation, per ICAO guidelines.

   If you have a specific country, let me know, I may be able to assist with
rules.

Dan ii

  _____  

From: Cary Renquist [mailto:cary.renquist at ezag.com] 
Sent: Wednesday, July 22, 2009 18:48
To: Dan W McCarn; radsafe at radlab.nl
Cc: sales at spectrumtechniques.com
Subject: RE: [ RadSafe ] UN2910 Labeling for EXEMPT Calibration Sources -
Yes orNo

Your total activity is under the exempt consignment limit for DOT and ICAO:

49 CFR 173.436; IATA 10.4.2.1

The total for all your sources is ~96% of the exempt consignment limit -
i.e. you do not have radioactive material... 

(not sure how well the table will survive...)

activity
 (uCi)

49cfr173.436 
(uCi)

%

Ba-133

1

27

0.037

Cd-109

1

27

0.037

Co-57

1

27

0.037

Cs-137

0.1

0.27

0.370

Mn-54

1

27

0.037

Na-22

1

27

0.037

Co-60

1

2.7

0.370

Zn-65

1

27

0.037

0.963

---

Cary Renquist

cary.renquist at ezag.com

-----Original Message-----
From: radsafe-bounces at radlab.nl [mailto:radsafe-bounces at radlab.nl] On Behalf
Of Dan W McCarn
Sent: Wednesday, 22 July 2009 06:49
To: radsafe at radlab.nl
Cc: sales at spectrumtechniques.com
Subject: [ RadSafe ] UN2910 Labeling for EXEMPT Calibration Sources - Yes
orNo

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)

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