Re: wrong DOT label/reply

[William V Lipton <liptonw@dteenergy.com>]

You should go a little further in the definitions.  See 49 CFR 107.3:
"'Transports' or 'transportation' means any movement of property by any mode, and
any loading, UNLOADING, OR STORAGE INCIDENTAL THERETO [emphasis mine]."  Thus a
person who unloads a hazmat package is a DOT "person,"  would be required to have
"hazmat employee training" and would be required to comply with any reporting
requirements.  Without knowing more details, I can't determine whether Irene
participated in the unloading of this package, or "storage incidental thereto,"
but this must be considered.

The opinions expressed are strictly mine.
It's not about dose, it's about trust.

Bill Lipton
liptonw@dteenergy.com


>
>
> I don't subscribe to radsafe, but read the archives.  You might want to
> consider the following:
>
> The key word here is "person."  According to the definition in 49CFR171.8,
> Irene is not a person.  Only those who offer a hazardous material for
> transport or who transport the material are persons.
>
> ---
>
> JHageman@swri.edu wrote:
>
> I don't want to belabor the point, but the the regulation [49CFR175.31(a)]
> clearly states: "Each person that discovers a discrepancy...
> shall...notify the FAA...
>
> ----
> John F. Fill
> johnboy@alumni.caltech.edu
>
>
>
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