[Fwd: Re: Shipping of spent Tc generators]

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

To give you the benefit of the doubt, you probably accomplished all of

this

before 49 CFR 172, Subpart H took effect, in 1994.  Since then, self

instruction is not adequate.   For one thing, this requires that each

hazmat

employee be trained and tested.  He must also be certified, and his

employer

must keep records of this training.  (Note that no minimum hours of

training is

specified, and there's no legal requirement that the hazmat employee

pass the

test.)



The opinions expressed are strictly mine.

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

Curies forever.



Bill Lipton

liptonw@dteenergy.com



Brian Rees wrote:



> 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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