Re: Shipping Limited Quantity of RAM

[Aquaman-Kerry Pate <patekp@musc.edu>]

Please correct me if I'm mistaken but...
Isn't a smoke detector classified as a "consumer commodity"
and therefore exemept from the labeling, markering etc.
requirements?  Most "individual" consumer products under
the scenario described by Tad would not require the
mover to act as a shipper as I understand it.  Three 
smoke detectors would be similarly classified (I believe)

Even so, the smoke detector would have to exceed 
0.5 millirem/hr in order not to be excepted under
49 CFR 173.421 through 173.422 and require some
type of "notice" as described therein

According to 49 CFR 171.8 (definitions) -paraphrased-
--------
Consumer Commodity:  a material that is packaged and distributed
in a form intended or suitable for sale through retail sales
agencies...for consumption of individuals for purposes of 
personal care or household use.

Furthermore, a smoke detector may be classifed as a life
saving device as well.

49 CFR 173.219: -paraphrased-
-----
(a)  A life saving device...containing small quantities of
hazardous materials which are required as part of the 
life saving appliance must conform to the requirements
of this section.
(c)  Materials therein...must be packaged in other strong 
outer packagings.

I don't have any idea about the static eliminator
containing PO-210 other than under 49 CFR 173.422 
exceptions for manufactured instruments.

Hope this helps.

Kerry Pate
MUSC
Environmental Hazards Assess. Program
Charleston, SC 29414


On Tue, 27 Feb 1996 Tad_Blanchard@ccmail.gsfc.nasa.gov wrote:

> Can someone provide some insight on the following "hypothetical" 
> situation?
> 
> A family is moving cross country to a new home.  They have packed all of 
> their belongings (INCLUDING THREE SMOKE DETECTORS containing a limited 
> quantity of Americium-241).  
> 
>         QUESTIONS:
> 
>         (1)  Is there some obligation on the part of the shipper (head   
> of household) to insure that the "package" containing the smoke 
> detectors is "...marked, labelled, ..." in accordance with 49 CFR?
> 
>         (1a) Would he/she be required to perform radiation readings on 
> the package surface and obtain surface wipe tests of the package?
> 
>         (2)  What happens if the transport company is not informed of 
> the material in the shipment and there's an accident on the highway?
> 
>         (3)  Can this senario occur in the "research" community where a 
> principal investigator installs... say... (a static eliminator 
> containing PO-210) in an experiment and ships the device via common 
> carrier?  
> 
> ****************************** /^\   /^\ ******************************* 
> Tad Blanchard                 /___\ /___\     NASA-Goddard Space Flt Ctr 
> Nat'l Health Svc, Inc              O             Greenbelt, Maryland     
> Sr Health Physics Tech            / \            Phone: 301-286-9157     
>                                  /___\                                   
>                      Tad.Blanchard@GSFC.NASA.gov                   
> ************************************************************************ 
> 
> 
>