Re: Transporting on campus

["John DeLaHunt" <jdelahunt@cc.colorado.edu>]

> A regional Special Agent with the USDOT from Cheyenne recently came over
> to give us a quick run-down on transportation regs. The bottom line was
> that, if you are transporting a hazardous material (and for DOT purposes,
> radioactive materials fit that description if they contain more than .002
> uCi per gram), and you are transporting it on a public road (city street)
> you must follow DOT regulations.

Ummm.  DoT regs apply (under HM-181, this includes hazardous wastes) for
ANY transportation on any Public Road (being defined as any
vehicle-accesible space that is not gated, guarded or fenced
24-hours-a-day).  This definition of Public Roads includes university-owned
streets.  The issue is access, not ownership.

> If each individual package contains less than the "limited
> quantity" of a radionuclide (see 49CFR 173.423) you are exempt from most
> of the packaging, shipping paper, certification, marking and labeling
> requirements. You just have to have a strong, tight container, with an
> outside radiation level less than 0.5 mrem/hr and less than 22 dpm/cm2
> removable contamination. The limited quantity for P-32 liquid, for
> example, is 3 mCi, for solids it's 30 mCi.

My understanding of the regs was that whenever you shipped anything that
was on the 172.101 table, you had to have a shipping paper, at least.
Also,  I didn't see anything exempting any package from the 173.421-1
requirements (which are specific...).

> On the other hand, if
> the package contains more than the limited quantity, you must have the 7A
> specification packaging, shipping papers, labeling and the whole nine
> yards.

Don't forget HM-126F training.....

> We asked him about the possible exemption of state
> universities from federal DOT regulations, but he said that, as long as
> the university receives federal funding (and almost 70% of our research
> is from US government grants), we would have to follow Federal
> regulations.

DoT regs apply to any "commercial" transportation.  "Commerce" is defined
in the DoT Dictionary as anything that isn't "governmental".  This
definition of "Commerce", according to MY DoT contact, includes education.

CAVEAT:

IF you material isn't a "Hazardous Waste" (under DoT's definition, not
EPA's or NRC's), and:

your state hasn't adopted HM-181, and:

the Federal Grant issue doesn't apply (I plead ignorance on this aspect),

THEN:

you may not _have to_ do any of this DoT compliance.

However, docket HM-200 (a proposed rule that just came out) extends DoT's
authority to all hazardous material shipments over all public roads, period.


> P.S.  See you at the conference in Laramie next month?

Yup.  ;-)

John

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*John DeLaHunt, EH&S      *The Colorado College       *
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