RE: Shipping Question

[Tom Morgan <tmorgan@ISOTOPEPRODUCTS.COM>]

This is an uncontrolled release of radioactive material and hence must be

reported under the provisions of 10 CFR 20 and/or applicable state

regulations.  Since the courier service was in direct control of the

material at the time of the incident, it is their responsibility to report

abandonment of the box.  However, I would expect/hope that all parties to

this incident would report it, and extent of their involvement, to the

proper authorities.  



The fact that the courier service does not have a license for radioactive

materials is irrelevant.  If they transport hazardous materials, they are

required to comply with US DOT regulations outlined in 49 CFR.  These

regulations mandate training of drivers transporting hazardous materials.  A

properly trained driver does not abandon radioactive materials on the

roadside. 



Thomas L. Morgan, Ph.D.

Director, Health Physics

Radiation Safety Officer

Isotope Products Laboratories



-----Original Message-----

From: Ed Stroud [mailto:ed.stroud@state.co.us] 

Sent: Tuesday, June 25, 2002 10:27 AM

To: radsafe@list.vanderbilt.edu

Subject: Shipping Question



Here's a shipping question for those interested. (This is an actual

incident)



A licensed nuclear pharmacy uses a private courier service to deliver

(and retrieve) unit doses and vials of medical isotopes to licensed

hospitals outside of their normal service area.  An incident occurs

where the courier, on a return trip from the hospital back to the

pharmacy, deliberately abandons a box of this material in a parking lot.

 A member of the public finds the box, which is marked and labeled per

DOT, and contacts the hospital.  The box is eventually returned to the

pharmacy.  Management at the hospital, nuclear pharmacy and the courier

service are aware of the incident.



Here are the questions.  Should this incident be reported to the

authorities? Why/why not?  If yes, who do you think is responsible for

reporting this incident to the authorities - the hospital, because they

were the shipper; the pharmacy, because they paid for the courier

service; or the courier service, because their driver abandoned the

material. The hospital and the nuclear pharmacy have radioactive

materials licenses. 



Comments/thoughts?



Ed Stroud

CDPHE

ed.stroud@state.co.us



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