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Re: International shipping regs
It's been a while, but that title (TS-R-1) sounds like what is on the books
now from the IAEA. If you look in the back, it lists all of the nations that
agree to international transport under these regs, however, some countries like
the U.S. have some domestic regs that are different.
If you're shipping SNM, you're going to need an export declaration and
approval from the NRC. I'm not sure of all of the situations in which you'll need
an export declaration from the Dept of Commerce, the form doesn't seem that
friendly because it has some fields related to taxes and commerce that a radman
is not typically exposed to. In the end, an export declaration isn't that
tough. I believe we also had to have documents related to the declared value of
the type B cask/freight container and the contents of the pkg.
You may also need a certificate of competent authority from each country your
package passes through. For example, before we could ship a type B pkg to a
specific country, we had to get a certificate from their competent authority
(DOT in U.S.) to say the C of C and the contents of the pkg were acceptable.
Potential significant lead time for a cert of comp auth, but typically you're
consignee on the other end can help in their country.
I can't find the reference right now, but if you look at the manifesting
requirements between the DOT and IAEA, there are subtle differences. For example,
you'll want to ensure the shipping name you use is acceptable to TS-R-1 and
there are one or two additional entries required to be with the basic
description we're use to. The A2 values are slightly different for some radionuclides,
and the philosophy of RQ is domestic only. If you're going by sea, the IMDG
is a carbon copy of the IAEA regs with the exception of some compatbility and
loading restrictions and emergency response instructions.
HRCQ doesn't have an international meaning, so when your placarded freight
container with the square background goes over seas, it's just a placard on a
white panel. However; when they ship it back empty, they need to know that the
placard shouldn't have the square background...
Go through, I believe 172.200 shipping paper entries and TS-R-1 and make a
table comparing and contrasting the regs. Build the basic description and
additional descriptors line by line and you'll find that an international manifest
is essentially the same as a domestic manifest with a few additions.
Lastly, I put some money on the table to have a third party SME come in to
check out my procedure for the specific type of international shipment I was
involved in. In the end, the manifesting, marking, and labelling were pretty
straight forward, the processes related to exports and certificates for package
approvals were the areas of real learning.
Glen