Re: Certification of Type A Packages

[L691731@LMSC5.IS.LMSC.LOCKHEED.COM]

     It is ultimately the responsibility of the shipper to demonstrate
that any specification package they use has passed the tests for that
specification. Authorized Type A packages are listed in 49 CFR 173.415.
Note that while DOT 7A containers are accepted as Type A, any shipper
must be able to provide the the test documentation that supports the
specification designation to the DOT on request. That is difficult if
you use someone elses package. You can show demonstration of compliance
with tests according to the conditions in 49 CFR 173.461. When you use
someone elses package you are basically relying on 173.461 (a)(2), and
accepting the fact that NEN has stamped "7A" on the box as a "...
previous, satisfactory demonstration of compliance...". You are still
left without good documentation of test compliance. It gets sticky if
you don't know what the package was actually certified by NEN to carry.
If you use it for something very different from what they tested it for,
a regulator would probably not let you get away with using their test
results to show compliance foryour ship ment. While the re-use of other
organization's packages is a common practice, many such users may not be
able to demonstrate the package meets the test requirements since they
won't really know how the package was tested. We ran into this at
Lockheed in regard to 55 gal. drums. While everyone and his/her
brother/sister uses them as 7A Type A, we couldn't find a decent set of
test results from any source we had. We ended up performing the whole
set of tests in-house, and have a beautiful set of compliance
documentation.

Steven Souza, Lockheed Missles and Space Co., Inc.
Alternate Radiation Safety Officer    tel (408) 742-0767
Sunnyvale, CA 94089                   fax (408) 742-0611
PROFS: SSOUZA  Internet: L691731@lmsc5.is.lmsc.lockheed.com
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Date: Wed, 22 Jun 94 11:16:21 -0500
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From: Ninni Jacob <njacob@gsosun1.gso.uri.edu>
To: Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
Subject: Re: Certification of Type A Packages
X-Listserver-Version: 6.0 -- UNIX ListServer by Anastasios Kotsikonas
X-Comment:  Radiation Safety Distribution List

Does anybody know if there is a new DOT regulation that says that all
TypeA packages have to be certified?
For example, if we re-use a RAM package from ,say NEN or ICN,to ship
out RAM, do we have to recertify the package, or is their certification valid?
Any info will be welcome.