Re: Interstate commerce

[LIPTONW@detroitedison.com]

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Although I don't have the exact definition, it should be noted that NRC 
Licensees are governed by 10CFR71.5(b) which states that, "If DOT regulations 
are not applicable to a shipment of licensed material, the licensee shall 
conform to the standards and requirements of the DOT specified in paragraph 
(a) of this section [for most part 49CFR172-177] to the same extent as if the 
shipment or transportation were subject to DOT regulations..."  In other 
words, if it's licensed material, DOT regs apply whether or not it's 
"interstate commerce."   
It should also be noted that a contractor of the federal government is also 
subject to all of the federal regs for all hazardous material, and that 
intrastate shipments of hazardous wastes and hazardous substances are also 
subject to DOT regs (see 49 CFR171.1).  We use the conservative approach of 
requiring compliance for all offsite hazmat transportation.  For example, our 
service vehicles, which don't leave the state, carry shipping papers for 
hazamat, such as gasoline, solvents, and bug spray, if they are above 
"consumer commodity" limits.  The drivers also receive hazmat employee 
training, and we are registered with the DOT.   
Bill Lipton 



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Subject: Interstate commerce
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Does anyone have a copy of the DOT definition of "Interstate Commerce?"

Thanks,
blhamrick@aol.com
Barbara L. Hamrick


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