Required documentation of test results for Type A packaging

[Bruce Pickett <SHEA136@KGV2.bems.boeing.com>]

 From: Bruce Pickett, The Boeing Company, Seattle, WA
       shea136@kgv2.bems.boeing.com

 I apologize in advance for the length of this posting.  I am
 soliciting discussion regarding what is required by a shipper to
 document the use of a Type A package for radioactive materials
 (RAM).  At the end of this note are two sections from  the
 US Dept. of Transportation in 49 CFR:173.415 & 173.601(l).

 I have a device containing a Type A quantity of RAM that must be
 returned to the manufacturer.  The manufacturer says that the
 device itself is USDOT Specification 55 packaging that was
 recertified as Type A.  I am not shipping the device until the
 manufacturer provides me with complete documentation of the
 tests, including packaging design.  The manufacturer has sent me
 a one page sheet that only shows the package passed the water
 spray, free drop, penetration, and compression tests, but nothing
 else (e.g. no data showing that the construction methods,
 packaging design, and materials of construction).  I contend that
 this is inadequate for me to use the Type A packaging, and have
 told the manufacturer that 173.415 tells me that, as a shipper of
 RAM, I have to have complete documentation of the testing of Type
 A packaging, and 178.601(l) specifies everything that a testing
 report is to contain; 178.601(l) also states that the manufacturer
 of the packaging must provide this on request to any users of the
 packaging. The manufacturer responds that 178.601 is for non-
 bulk packaging and is not germane to transportation of RAM and
 that what they have provided is sufficient.

 The manufacturer is a reputable company and has distributed
 these devices for years.  I assume that the manufacturer knows its
 business and that USDOT has inspected them (and yes, I know what it
 means to "ass-u-me" anything).  I am not sure why the
 manufacturer is resistant to providing me with the information I
 have requested, but I'm guessing that maybe there is some
 proprietary information in their engineering design package.

 I realize that there is a lot of information missing from this posting
 (even as voluminous as it is), but does anyone on RADSAFE want
 to comment on whether or not they think the test results that I've
 been provided on signed manufacturer letterhead are sufficient
 documentation to satisfy the USDOT requirements?

 ------------------------ 49 CFR Excerpts Follow -------------------------

 173.415  Authorized Type A packages.

 The following packages are authorized for shipment, if they do not
 contain quantities exceeding  A1  or  A2  as  appropriate:
 (a)  U.S. Department of Transportation (DOT) Specification 7A
 (178.350 of this subchapter) Type A general packaging.  Each
 shipper of a Specification 7A package must maintain on file for at
 least one year after the latest shipment, and shall provide to DOT
 on request, a complete documentation of tests and an
 engineering evaluation or comparative data showing that the
 construction methods, packaging design, and materials of
 construction comply with that specification.  Specification 7A
 packagings designed in accordance with the requirements of
 178.350 in effect on June 30, 1983, and constructed prior to July
 1, 1985, may continue to be used.  Packagings either designed
 or constructed after June 30, 1985, must meet the requirements
 of 178.350 applicable at the time of their design or construction.
 (b)  DOT Specification 55 metal-encased shielded packaging
 constructed before April 1, 1975.  Such packaging constructed
 after March 31, 1975 is not authorized unless it is requalified
 under DOT Specification 7A.  Each packaging designed for
 liquids must also meet the requirements of 173.412 (m) and (n).
 Use of this packaging as DOT Specification 55 is not authorized
 after June 30, 1985.
 (c)  Any Type B, B(U) or B(M) packaging pursuant to 173.416.
 (d)  Any foreign made packaging that bears the marking "Type A"
 and which was used for the import of radioactive materials.  Such
 packagings may be subsequently used for domestic and export
 shipments of radioactive materials.  These packagings shall
 conform with requirements of the country of origin (as indicated
 by the packaging marking) applicable to Type A packagings.

 178.601  General requirements.
 ...
 (l)  Records retention.  Following each design qualification test
 and each periodic retest on a packaging,. a test report must be
 prepared.  The test report must be maintained at each location
 where the packaging is manufactured and each location where
 the design qualification tests are conducted, for as long as the
 packaging is produced and for at least two years thereafter, and at
 each location where the periodic retests are conducted until such
 tests are successfully performed again and a new test report
 produced.  In addition, a copy of the test report must be
 maintained by a person certifying compliance with this part.  The
 test report must be made available to a user of a packaging or a
 representative of the Department upon request.  The test report,
 at a minimum, must contain the following information:
 (1)  Name and address of test facility;
 (2)  Name and address of applicant (where appropriate);
 (3)  A unique test report identification;
 (4)  Date of the test report;
 (5)  Manufacturer of the packaging;
 (6)  Description of the packaging design type (e.g. dimensions,
      materials, closures, thickness, etc.). including methods of
      manufacture (e.g. blow molding) and which may  include
      drawing(s) and/or photograph(s);
 (7)  Maximum capacity;
 (8)  Characteristics of test contents, e.g. viscosity and relative
      density for liquids and particle size for solids;
 (9)  Test descriptions and results; and
 (10) Signed with the name and title of signatory.