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Re: Shipping of spent Tc generators
Someone's probably going to turn a flamethrower on me, but I've been an HP
too long to not have asbestos embedded in my clothing, skin, etc.
BUT..., so what's instruction? Mine consisted of my boss at the time
saying "here's 49 CFR, read it, figure it out, and do it right". It was
painful (for me) but 49 CFR DOES tell you what and how to do it. It took me
the better part of a couple of days to figure it out, but I did. I double
checked with the HP that worked for the transportation company (who I'm
forever indebted to, and will remain nameless so others don't run to him
all the time - you know who you are! thanks again) but I shipped materials
successfully hundreds of times, and did an honest job of it too.
I know there are plenty of corollarys in the HP field for reading the books
and doing the right thing, but if you follow the regs, what's the
issue? Of course, if you screw up, stand by, but I'm tired of far
exceeding the intent of the regulations because of "someone's"
interpretation. What's the instruction in my case? Self-instruction. My
employer was liable if I screwed up, but they were liable for the screw-up
anyway, no matter what my defense was. I've been to a transportation class
since, and it was easier than working through things myself, but didn't
have any divine revelations either.
All that said, I'd rather not do numerous shipments of hazardous materials
without extensive formal training, there are too many sharks in the waters.
(Quite obviously) my own personal opinion, and not that of anyone or
anything else's.
Brian Rees
At 07:31 AM 1/29/2004 -0500, you wrote:
>As a start read the regulations, especially 49 CFR 172, Subpart H. One
>excerpt: 49 CFR 172.702(b): "... a hazmat employee who performs any
>function subject to the requirements of this subchapter may not perform
>that function unless instructed in the requirements of this subchapter
>that apply to that function..." In other words, don't ship radioactive
>material unless you've been trained to do it properly. You're question
>indicates that you have not had this training.
>
>liptonw@dteenergy.com
>
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