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Transportation Changes July 1



1.  HM-215D was published on Thursday, June 21, 2001 which authorized the use 

    of the ICAO 2001-2001 Technical Instructions (and hence IATA-2001 

    Appendix G) for the shipment of radioactive materials pursuant to the 

    limitations in 49 CFR 171.11 beginning July 1, 2001.  It also authorized 

    the use of 20 out of the 25 new proper shipping names and UN numbers for 

    surface shipments not associated with air transport.



2.  It is most important to recognize that ICAO/IATA does not stand alone as 

    an independent set of transportation regulations, but may only be used to 

    the extent permitted by 49 CFR 171.11.



3.  This sets the stage for implementation of the ICAO/IATA regulations on 

    July 1, 2001 by FedEx Express and other air carriers who require the use 

    of the IATA regulations.



4.  Note that 49 CFR 171.11 retains the use of the 49 CFR Type A quantity 

    values and the 70 Bq/g definition for radioactive material.  This means 

    that in order to comply with both the 49 CFR and IATA requirements that 

    the smallest applicable A1 or A2 values between the 49 CFR and IATA 

    Type A quantity tables must be used.  Also the smaller value between 

    70 Bq/g and the ICAO/IATA "activity concentration for exempt materials" 

    as limited by the "activity limit for exempt consignment" must be used.



5.  Note that excepted packages of limited quantity of materials; articles 

    manufactured from natural or depleted uranium or natural thorium; 

    instruments and articles; and empty packages will have individual UN 

    numbers.



6.  Note that the UN number for excepted packages is now a marking 

    requirement under ICAO/IATA.



7.  Excepted packages must have the "excepted package" statement as required 

    by 49 CFR even under ICAO/IATA shipments.



8.  Fissile material shipments under ICAO/IATA will now require  separate CSI 

    "Critically Safety Index" labels in addition to the normal Radioactive 

    category labels, White I, Yellow II and Yellow III.  Plutonium-238 is no 

    longer classed as fissile material.



9.  DOT specification packages, 6M, 20WC, and 21WC, do not have an applicable 

    proper shipping name under the new IAEA TS-R-1 (ST-1, revised) system.  

    FedEx plans to implement a policy exception permitting the domestic 

    shipment only of these specification package using the old proper 

    shipping names and UN numbers for the few years remaining for the 

    permitted use of these specification packages.



10. Since "special form" is no longer included in the Type B package proper 

    shipping names it is necessary to enter "special form" on the shipping 

    paper, which is the Quantity and Type of  Packaging column on the IATA 

    Dangerous Goods Declaration.





Roy A. Parker, Ph.D.

E-Mail: roy@royparker.org

Tel: 225-924-1473

Fax: 225-924-4269

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