Re: Transporting on campus

["John DeLaHunt" <jdelahunt@cc.colorado.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.

Wow.  I'd like to see that in writing....  The verbals I got were contrary
to this. 

> 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'

The limited qty is (from Table 7) for materials package limits, liquids,
other, is 10E-4 A(2).  Anyone want to hazard a guess at what the A(2) is?

> 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.

Why can't they extend the same curtesy to hazmats....

*growl*

John

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