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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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