Re: DoT rules (49CFR)

["ruth_weiner" <ruth_weiner@email.msn.com>]

If this is just a remnant of the days when RAM was treated as particularly
>strange then why has it persisted in the rules?

I suspect it persists largely because, like every other agency, DOT
hesitates to make a rule appear less stringent - and it is a "remnant."  A
truly dumb result of this sort of thinking is that FedEx doesn't want to put
radioactive material with the other HAZMAT directly behind the pilots in the
FedEx planes, so the RAM is randomly distributed throughout the other cargo.

Ruth F. Weiner, Ph. D.
7336 Lew Wallace NE
Albuquerque, NM
505-856-5011
fax 505-856-5564
ruth_weiner@msn.com
-----Original Message-----
From: Lester Slaback <Lester.Slaback@NIST.GOV>
To: Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
Date: Wednesday, March 15, 2000 2:29 PM
Subject: 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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