RE: A shipping query

[Tom Morgan <tmorgan@ISOTOPEPRODUCTS.COM>]

Joel,

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.

 A reminder:

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
661-309-1010
661-309-8303 (fax)

[Tom Morgan]  -----Original Message-----
From: Joel Baumbaugh [mailto:baumbaug@NOSC.MIL]
Sent: Tuesday, April 17, 2001 8:42 AM
Subject: A shipping query

        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)