Re: Interstate commerce

[jdelahunt@cc.colorado.edu (John DeLaHunt)]

> 10 CFR 71.5 (b) basically says for licensed material
> you must follow DOT regs for ALL transport off site as if it were an 
> interstate shipment.  Most agreement states have followed suit. 

That off-site concept is sticky, too.

DOT defines a "public road" as anyplace that isn't gated, guarded or blocked
24 hours a day.  That is, if you can control (i.e. eliminate) access to the
road you want to use by the public, you can avoid meeting the HM-181 rules.

Near as I can tell, this means any shipment, even on your property, must
meet 181, unless you've controlled, to zero, public access to the shipping
route.

John

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