Instrument check sources may be exempt quantities, however, 10CFR20 is not the place to look for shipping regulations. 49CFR, the D.O.T. shipping regulations, has what you need. Here is a brief summary:
1. Radioactive materials meeting the limited quantity definition of 49CFR173.425 may be shipped in excepted packages, as described in 49CFR173.421 and 173.424. For example, 1 uCi Cs-137 check source is less than less than 0.01 times the A2 value for Cs-137 (13.5 Ci) (see Table 7 in 49CFR173.425 and 173.435).
2. "Excepted packaging" means that the radioactive material and its packaging is excepted from the specification packaging, marking and labeling, ..., the shipping paper and certification requirements of this subchapter... (49CFR173.421(a)).
3. However, you ARE required to include the statement described under 49CFR173.422(a)(2) about conforming with 49CFR173.424 for instruments.
Bottom line: Shipping papers (Dangerous Goods Declaration) are not required, but a simple one paragraph statement included in the packing list or inside the shipping container is required per paragraph 3 above.
Don't forget the "Rule of Tens" when it comes to exempt quantity sources. If your license is issued under the provisions of 10CFR32.18 (Manufacture, distribution and transfer of exempt quantities of byproduct material: Requirements for license), not more than 10 exempt sources may be transferred in any one transaction (10CFR32.19(a)), each must be individually packaged and no more than 10 such packages may be contained in one outer package (10CFR32.19(b)).
Thomas L. Morgan, Ph.D.
Director, Health Physics
Radiation Safety Officer
Isotope Products Laboratories
24937 Avenue Tibbitts
Santa Clarita, CA 91355
[Tom Morgan] -----Original Message-----
From: Joel Baumbaugh [mailto:baumbaug@NOSC.MIL]
Sent: Tuesday, April 17, 2001 8:42 AM
Subject: A shipping query