A shipping query

[Joel Baumbaugh <baumbaug@NOSC.MIL>]

        

Hello

all,

        

I work for

the U.S. Navy and am currently "butting heads" against an

"immovable object" (Administratium) and

wondered if perhaps I was interpreting the U.S. Federal regulations in a

"weird and twisted way" (as I am sometimes apt to do) or if I

was just hoping for a ray of light at the bottom of a deep dark well

(sigh).

        

There

seems to be a conflict with the current U.S. Navy requirements for

shipping Radiation Survey Meters with check sources (as "limited

quantity" packages), and 10CFR30.15(9) Ionizing radiation

measuring instruments containing... which "appears" to put

survey meters in a different and unique "classification" than

other radioactive sources of the same quantity...

        

My two

quick and (perhaps not so) simple questions are:

        

1. Do

Survey Meters which contain sources which are less than one exempt

quantity, as a check source (less than 10CFR30.71) need "shipping

papers" to transport them from one location to another over public

roads? They "appear" to be exempt from those requirements by

30.15 due to their (and the other exempted items listed)

"unique" classification.

        

2. As I

transport them, do I need to include appropriate the 49CFR notice of

173.422? Again, due to their "unique" classification, it

appears that the authors of 30.15 realized that survey meters needed to

be "mobile" as they often need to be "utilized" in a

hurry, and so could do without the normal "paperwork" needed to

transport radioactive material.  If I do include the notice and call

them "excepted radioactive material, limited quantity, n.o.s., I'd

be mis-labeling my package!

        

The reason

I ask this is that they "appear" to fall under the same

exemptions given to Exempt Concentrations (10CFR30.14) and

Certain items containing byproduct material (10CFR30.15) which do

NOT require shipping papers because they have been exempted into a

"unique" classification (along with electron tubes,

wrist-watches, compasses, etc.), which IMHO, are NOT meant to be

covered/governed under 49CFR.

        

At this

time, I am shipping all survey meters as "Limited Quantities of

Radioactive Materials" under 49CFR, and I feel that it is

costing my Command MANY thousands of dollars a year (in training and

shipping) which, IMHO, could best be spent somewhere else.

        

I would

appreciate any comments/suggestions (let's keep it clean here) and

dialog, which would help ME come to an understanding on this

subject.  You know, I've been in this "business" for over

20 years and its the "gray" areas that give me the most

headaches (grin)...

        

Thanks

(and I apologize for multiple postings on other

"lists"...),

        

Joel

Baumbaugh (baumbaug@nosc.mil)