Re: Mislabeling

["Don Jordan" <ramservices@lsol.net>]

10 CFR 20.1904 requires labeling of containers of licensed material (in
excess of Appendix C amounts) with the CRM warning and also with information
describing the contents.  By inference, applying this label where it does
not accurately describe the contents would be an implicit violation.

Radiation Areas are defined in the regulations (10 CFR 20.1003) and applying
such warning signs where the definitions were not met would also, I presume,
be implicitly prohibited.  How this would actually be enforced probably
depends on the circumstances and the inclination of the inspector.

I would guess that CA has very similar regulations.

Mis-placarding is covered in 49 CFR 172.502

I formerly worked at a research university.  One day while walking thru the
tunnels to get to a bio research building I noticed that one of our resident
geniuses  had used about 100 feet of CRM tape along the tunnel walls,
apparently to guide a visitor to the correct building.  Unfortunately, they
didn't use it all the way to the lab.

My son once asked if I could give him a CRM door sign to put on his bumper.
He didn't seem too concerned about the illegality, but I did advise him that
he would make many new friends in the State Police if he did it.

Don Jordan
RAM Services, Inc.
ramservices@lsol.net
Tel. 920-793-2259
Fax 920-793-5886

2306 West River Street
Two Rivers, WI  54241
----- Original Message -----
From: Grimm, Lawrence <LGrimm@ADMIN.UCLA.EDU>
To: Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
Sent: Friday, July 21, 2000 5:39 PM
Subject: RE: Mislabeling


> Alright!  Dave Pratt has shown that it is illegal to offer or carry a
> mislabeled package in 49 CFR 172.401.  Is it illegal to mis-placard a
> vehicle?
>
> I'm still looking for a prohibition in 10 CFR or an Agreement State's
> radiation regulations for the misuse of the "Caution - Radiation" signs.
>
> Larry Grimm
> UCLA EH&S/ Radiation Safety Division
> * lgrimm@admin.ucla.edu   Phone:310/206-0712   Fax: 310/206-9051
> * On Campus: 501 Westwood Plaza, 4th Floor, MS 951605
> * Off Campus: UCLA Radiation Safety Div, 501 Westwood Plaza 4th
> Fl, Box 951605, Los Angeles, CA 90095-1605
> * If this email is not RSD business, the opinions are mine, not
> UCLA's.
>
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