Re: Excepted Packages of RAM, ICAO, IATA, etc.

[Jeff Pettigrew <jpettigrew@halnet.com>]

Dear Radsafers,

Coincidentally and prior to this topic on Radsafe,  I had recently spoken
with Christopher Glasow of the (DOT)Federal Aviation Administration with
respect to the subject of carriage of limited quantities of ram aboard
passenger aircraft.  To summarize, it is in fact, perfectly legal to carry
"excepted packages" aboard passenger aircraft as long as the provisions of
49 CFR 173.421, 173.421(a),173.422, et al are followed. Note that the
numbering scheme of these regulations have changed as published in the
28Sept95 Federal Register, 173.421a will become 173.422, etc.  No Shipper's
DGD or labelling is required, however a statement must accompany the package
as described within the regs.

As per 49 CFR 171.11 The ICAO (IATA) regs my be used in the U.S. with the
addition of certain U.S. required information (variations), such as RQ and
emergency response information.  In the case of excepted packages, no
Shipper's DGD is required.  This information is found in section 10.5.9 of
the IATA DG regs.  There are two notations within this section stating:
Categorization, Labelling and Shipper's Declaration are NOT (emphasis
theirs) required. Pehaps this means what it says.  The IATA regs are suppose
to be 100% in compliance with the ICAO Technical Instructions with the
addition of the Airline Limitations. However, it does not have the authority
of law as the ICAO TI does.  I do not see any explicit Airline Limitations
forbidding excepted quantities of ram in the 1996 IATA regs. Although one
might infer that Lufthansa does not allow "limited quantities" of
radioactive materials,  in fact they do.

Do not confuse EXEMPT (from licensing by NRC/Agreement States) with EXCEPTED
from 
dangerous goods regulations. They are different. Although in general an
exempt source most likely could be shipped as an Excepted Package, as long
as it meets the requirements of dose rate, (strong tight)packaging, etc.

In spite of the legality of carrying excepted packages aboard aircraft, it
may not be prudent to do so as most airline employees have no awareness of
the above.  The persons managing the the security check points are not
trained in the finer points of the regs. You might be right and miss your
plane trying to prove it.  Mr. Glasow (202-267-3952) said he can help
individuals wanting to carry excepted packages aboard passenger aircraft, if
they contact him prior to your intended flight. You should decide for
yourself the liklihood of having a problem and the amount of time and energy
to expend (hassle-factor) in trying to do what's legally allowable vs. just
Fedexing the darn thing ahead of you.  I have personally attempted to get a
policy clarification/confirmation of the above from a major airline HQ'd in
Houston and I can vouch that no one on the lower rungs of the company ladder
has any idea about ram other than it is FORBIDDEN.

One wonders how the NRC or IAEA employees get their survey meters and check
sources from one place to another. Via passenger aircraft? Comments?

Jeff Pettigrew
jpettigrew@halnet.com




 **********************************************************************
 Jeffrey S Pettigrew                    Voice: 713.496.8319         
 Radiation Safety Officer                 Fax: 713.496.8394
 Halliburton Energy Services
 PO Box 42800                
 Houston, TX 77242-8042                   jpettigrew@halnet.com
or   
                               esg.gvrz301@mhs-halco.attmail.com 
                              
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