Re: ram in transit

[TracyJW@lhp25.nist.gov]

This depends on whether or not your are a licensed facility.  

If you are not a licensed facility (eg. freight fowarder, carrier, etc.) posting is not 

required.  Radiation safety requirements pertaining to the storage of material in transit are 

given in 49CFR173.447.  Basically exposures are controlled by limiting the number of packages in 

an area such that the total TI is less than 50.

If you are a licensed facility you are not exempt from posting as a radiation or a high 

radiation area, as required.  You are however exempted from labeling the container 

(10CFR20.1905) and access controls for high radiation areas (10CFR20.1601).  Under the old 

10CFR20 licensees were exempt from the posting requirements.  With the new 10CFR20 this 

exemption was removed.  If you look at a copy of the final rule for the new 10CFR20 this point 

is specifically addressed in the summary of public comments on the new rule.  The NRC's view is 

that "there should be posting of these areas because there is no restriction on the length of 

time that packages may remain in a room"


Jim Tracy
tracyjw@lhp25.nist.gov

Usual disclaimer - All views are my own.  My employer did not review/approve this message.
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