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DoT rules (49CFR)
As I read thru IAEA ST-1 question a arise as to why certain requirements
exist. The question for today is:
Why do Class 7 (radioactive) hazardous materials have to be segregated from
other dangerous goods? If there is an issue with one particular type of
dangerous material (for instance, explosives), why not just identify that?
If this is just a remnant of the days when RAM was treated as particularly
strange then why has it persisted in the rules?
Note that there is a separate segregation requirement regarding film, but
this is not a dangerous goods issue.
On another note, with the ST-1 definition of what is Radioactive Material
(i.e., material requiring transportation regulation) many folks might find
that their shipments of radwaste will be exempt from DoT rules. That is,
it is not hazardous material for shipping purposes but must be disposed as
hazardous material. But of course this will only happen if DoT gets
comments endorsing ST-1.
Disclaimer: the above are the personal musings of the author, and do not
represent any past, present, or future position of NIST, the U.S. government,
or anyone else who might think that they are in a position of authority.
Lester Slaback, Jr. [Lester.Slaback@NIST.GOV]
NBSR Health Physics
Center for Neutron Research
NIST
100 Bureau Dr. STOP 3543
Gaithersburg, MD 20899-3543
301 975-5810 voice
301 921-9847 fax
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