Re: Transporting on campus

[EFJ@asbhr.byu.edu]

>
> So, the question came up today around the office, how do other
> Universities handle the transportation of waste and isotopes on
> campus.

I called RSPA and the interpretation I got was that if we remain on
our own property we are not "in commerce" and therefor not subject to
Subchapter B of 49 CFR regarding hazardous material transportation.
If we use a public road then we are "in commerce" and subject to
regulation.

There are numerous exceptions provided for articles, insturments, and
limited quantities.  (see 173.421 - 173.425)

49 CFR 173.421 provides an exception from "specification
packaging, shipping paper, and certification, marking and labeling
requirements if ..." you have a limited quantity and:
    a. packed in a strong package
    b. rad level less than 0.5 mrem per hour
    c. no surface contamination
    d. package is marked 'radioactive'

There are a few other sections but you would probably enjoy reading
173.421.

In addition there are specification package, marking, and labeling,
(note not shipping paper) exceptions for low specific activity
material transported as exclusive-use shippments.








______________________________________________________________________

Name: Edwin Jackson
EFJ@ASBHR.BYU.EDU
Environmental Coordinator
Brigham Young University
(801)-378-5779