Re: Required documentation of test results for Type A packaging

[TracyJW@lhp25.nist.gov]

//>  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 correct in that 178.601 is not applicable.  178.600 states that this 

subpart (m) is for performance oriented packagings identified in subpart L (178.500).  The 

packagings for radioactive material, spec 7A are described in section K "Specifications for 

Packaging for Class 7" (178.350).  Since your Spec 55 drum was requalified as USDOT spec 7a 

Sections 178.350-1 thru 178.350-3 are applicable for your package.

  As far 173.415 goes - it states that you must maintain on file "complete documentation of 

tests and engineering evaluation or comparative data showing that the construction methods, 

packaging design, and material of construction comply with that specification".  I've always 

taken this to mean you need to show that you meet the requirements listed in 173.24, 173.411 and 

173.412 and the performance tests (drop, water spray, etc.).  If you read the requirements here 

you'll find that except for the performance tests the requirements are fairly generic.  You can 

probably go thru them yourself and document that the packages meets the requirements.

  We have designed and tested our own packages here (generally cardboard boxes).  When I 

document the results I write a little description of the package; include a statement that the 

package meets the applicable design requirements in 173.24, 173.411, and 173.412; and include a 

copy of the performance testing results.  We have had our documentation inspected by the NRC and 

they were satisfied by this (although in my opinion all they were interested in was the 

performance test results).  

I'd recommend that you either ask the manufacturer for a statement that the package meets the 

above design requirements or go ahead an document it yourself.  For you results include a copy 

of this with the performance testing results. 

  Hope this helps.  If you need any more infor please feel free to contact me.
                                                    Jim Tracy
                                                    tracyjw@lhp25.nist.gov