US DOT excepted package statements

[Roy Parker <RoyAParker@COMPUSERVE.COM>]

Sherry,



This seems to be addressed in HM-215D, published June 21, 

2001.  Section 171.14(d)(2) states:



"Intermixing old and new requirements. Prior to October 1, 

2002, it is recommended that the hazard communication 

requirements be consistent where practicable. Marking, 

labeling, placarding, and shipping paper descriptions should 

conform to either the old requirements of this subchapter in 

effect on September 30, 2001, or the new requirements of 

this subchapter in the June 21, 2001 final rule without 

intermixing communication elements. However, intermixing is 

permitted, during the applicable transition period, for 

packaging, hazard communication, and handling provisions, as 

follows: 



It would appear that "it is recommended that the hazard 

communication requirements be consistent where practicable" 

permits the new UN number for excepted package components to 

be substituted as appropriate.  e.g. This package conforms 

to the conditions and limitations specified in 49 CFR 

173.428 for radioactive material, excepted package - empty 

package, UN2908.





Roy A. Parker, Ph.D.

E-Mail: roy@royparker.org

Tel: 225-924-1473

Fax: 225-924-4269





> It looks like 49 CFR 173.422 was not amended in DOT's 

> recent rulemaking to incorporate the new UN numbers and 

> proper shipping names from IATA.  If an excepted package 

> is going by air, it will have a new UN number on the air 

> waybill, a new UN number marked on the package, and an old 

> UN number on the excepted package certification required 

> at 173.422 by DOT.  In the interest of harmony, I am 

> hoping the DOT would accept an excepted package 

> certification such as "This package conforms to the 

> conditions and limitations specified in 49 CFR 173.428 for 

> radioactive material, excepted package -- empty package, 

> UN2910 and UN2908."  Any advice?

>

> Sherry Meith, CIH, CHP

> Boeing Radiation Health Protection

> PO Box 3707, mailstop 6Y-38

> Seattle, WA  98124

> 425/393-1812

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