Re:

[William V Lipton <liptonw@DTEENERGY.COM>]

You do NOT need training every 2 years.  There is a DOT letter of

interpretation available on the hazmat safety home page.  Look for the

interpretations for 49 CFR 172.702.  It's a letter to John Nipper, dated May 6,

1997.  It states:



"A shipper who uses the ICAO Technical Instructions for the transport of

hazardous materials, domestically or internationally, must be re-trained at

least once every three years in accordance with paragraph 172.704(c).  Although

a shipper offers hazardous materials in accordance with the ICAO Technical

Instuctions, as provided in paragraph 171.11, the shipper is not subject to the

carrier training requirements of the ICAO Technical Instructions."



The opinions expressed are strictly mine.

It's not about dose, it's about trust.

Curies forever.



Bill Lipton

liptonw@dteenergy.com



"William G. Nabor" wrote:



> Dear Radsafers:

>

>     The U.S. DOT regulations require shippers of radioactive material to be

> retrained every 3 years.  IATA says every 2 years.  I have in my notes from

> Roy Parker's class that the U.S. adopted IATA, but cannot find chapter and

> verse.  Dr. Parker, are you out there?  I need to prove (by quoting some

> regulation) that I need retraining every 2 years.  No credit given for

> deducing why this is needed.  Or, if it's the case, why IATA's 2-year

> requirement doesn't apply.  Can anybody help?  Thanks.

> ---------------------

> W. G. Nabor

> Senior Health Physicist

> University of CA, Irvine

> WGNABOR@UCI.EDU

>

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