Re: DOT Record Keeping

[EFJ@asbhr.byu.edu]

> 49 CFR 173.415(a) requires that each shipper of a DOT Specification 7A Type A
> package must maintain on file for at least one year after the latest shipment
> a complete documentation of tests and an engineering evaluation or comparative
> data showing that the construction methods, packaging design, and materials of
> construction comply with the specification as described in 49 CFR 178.350.
>
> What types of engineering analysis are licensees who transport nuclear gauges
> off-site performing in regard to the requirement, and what sort of records are
> you keeping.  The Type A packages that I'm referring to are the one's supplied
> originally by the manufacturer (CPN and Troxler).

Our Troxler gauge came with a "Type A Package Certification" that
basically says that the package is in compliance with DOT
regulations and that the engineering and testing data are on file at
Troxler Electronic Laboratories.

We have depended on this certification in the past, however after
rereading 173.415 I called RSPA (the Reserach and Special Programs
Administration of the Department of Transportation) and asked if the
certification would satisfy the requirement.  The young lady from
RSPA I talked with stated that this certificate did not meet the
needs and that I should have the complete testing and engineering
data on file.  I have requested this data from Troxler.

The DOT Standards Division telephone number is (202) 366-4488 this is
the group that is authorized to interpret the HAZMAT shipping
regulations.






______________________________________________________________________

Name: Edwin Jackson
EFJ@ASBHR
Environmental Coordinator
Brigham Young University