Re: Transporting on campus

[EFJ@asbhr.byu.edu]

> 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?
>

John has a point.  The regs are not always easy to read and use.  In
this case to use Table 7 you need to know what 'special form' means
(see 173.403)  and the location of the Table for A1 and A2 values
(see 173.435).  In addition tests for special form materials are given
in 173.469.  The A2 value for 14C normal form is 60 Ci.  Hence I am
allowed to transport up to 60 mCi(10-3) of dry waste under the limited
quantity exceptions.  For P32 the limited quantity for dry waste
would be 30 mCi.

The term 'in commerce' is the basis for the definition of hazardous
materials.  Sec 104 of USC 1801 (Hazardous Materials
Transportation Act) states:

     "Upon a finding by the Secretary, in his discretion, that
    the transportation of a particular quantity and form of material
    IN COMMERCE may pose an unreasonable risk to health and safety or
    property, he shall designate such  quantity and form of a
    material or group or class of such materials as a hazardous
    material."

This is not the regulation; however, it is the statute upon which the
regulation is predicated.  If you are not 'in commerce' you are not
in the book (under the regulation).  Different people have different
interpretations as to what 'in commerce' means.  The DOT Standards
group is the only group authorized to give an official interpretation
of the transportation regulations.  Their telephone number is 202-366-
4488.  Interpretation of the statute is usually done by the courts.

I noticed one comment that a LSA shippment did not need specification
packaging.  This is only true if the shippment is an exclusive-use
shippment which allows us to use 173.425 (b).  Otherwise we are under
173.425 (a) which still requires spec. 7A package even for an LSA
shippment.

The small quantity exception (173.4) differes from the limited
quantity exception 173.421, but not by a whole lot when shipping
radioactive material.  I have found 173.4 very useful when
shipping chemical samples.

______________________________________________________________________

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