Re: Required documentation of test results for Type A packaging

[a.zapantis@qut.edu.au (Alex Zapantis)]

> 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?
>

I think the declaration from the manufacturer of the package will suffice. I
assume your regs are based on IAEA Safety Series # 6. If so you will note
that no certificate from a "competent authority" is required for Type A
containers whereas one is required for Type B containers.

I have had a fair amount of experience with designing and testing containers
for compliance with type A container requirements. Let me tell you that to
meet the requirements, one does not need an "engineered" package. For
example, a simple steel box with a lockable hinged lid, sources in lead pots
in the box packed with vermiculite packing passes all Type A tests with
flying colours.

As far as the water spray test goes, it is only relevant to "cardboard"
containers.

I probably haven't helped you at all since I do not know your regs however I
have thrown my two cents worth in anyway.

Regards


                I know that you believe you understand what you think I said 
                but I am not sure that what you heard is actually what I meant.

                        Alex Zapantis
                        Radiation Safety Officer                               
                        Queensland University of Technology          
                        Health & Safety Section                             
                        Locked Bag No.2
                        Red Hill Qld 4059
                        AUSTRALIA

                        Ph     : 61 7 864 3566
                        fax     : 61 7 864 3993
                        email  : a.zapantis@qut.edu.au