Re: wrong DOT label

[Don Edling <dedling@home.com>]

Some general information:

1.	Discussions with DOT personnel in the past has led me to 
	conclude that there is no documented requirements for reporting 
	events of this nature to the DOT - either by the receiver or by 
	the shipper. The DOT has indicated that such a communication 
	(from the receiver or person identifying the discrepancy to the 
	shippers) is an excellent practice.

	Note the above words "of this nature," since there are reporting 
	requirements for serious events (person/people killed, even 
	suspected release of radioactive contamination. etc.) as given 
	in 49CFR171.15

	Someone mentioned 175.31 as requiring immediate notice to the 
	FAA if it went by air. I guess this would have to be explored 
	further as to the exact intent.

	This discussion does not address any NRC or DOE requirements for
	notifications, just the DOT.

2.	A table from 49CFR 172.403 is summarized below:

	Transport Index		Max Rad. level		Label Req.
	_________________________on surface_____________________________

	0.0*			< 0.5 mrem		White-I

	> 0.0, < 1    		> 0.5, < 50 mrem	Yellow-II

	> 1, < 10		> 50, <200 mrem		Yellow-III	
________________________________________________________________

	* If measured TI is less than 0.05 it may be considered to 
	  be zero (0).

	One has to meet both requirements for a specific label to be 
	authorized. Also, in some cases above it may be greater than or 
	equal to, but I have not include the "equal to" signs for 
	simplicity.

	Your package - 1.2 mr/hr at a surface point would be a Yellow-II

3. 	Someone also said this should be in a Type A package. the table 
	below gives the content ranges for Type A quantities. from the 
	input below I can not determine specifically that a Type A 
	package would be required - unless someone makes added 
	assumptions such as air shipments, etc.

		Type A quantity range: A1 = 8.11 Ci & A2 = 8.11 Ci

		Lower limit		Upper limit
		____Ci_____________________CI__________________

Solid		0.008 Ci		8.11 Ci
(normal)

Solid   	0.008 Ci		8.11 Ci
(Special)

Liquids		0.0008 Ci		8.11 Ci

Thus, one would look at the table and decide, depending on the form
(liquid or solid) and the Ci content, whether a Type A package was
necessary - excluding any other assumptions.


Irene K Sakimoto wrote:
> 
> Hi Everyone,
> 
> We recently received a package of P-32 radioisotopes labeled with a White
> I but measured 1.2 mR/hr on the exterior of the package.  Therefore, it
> should have been labeled with a Yellow II, right?
> 
> We called the shipper and the carrier about the error, but should we have
> notified anyone else?
> 
> Thank you for any insight you may have on this topic.
> 
> Irene Sakimoto
> 
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