Dot reg. questions (new rule)

["Les Slaback, Health Physics" <SLABACK@micf.nist.gov>]

 The new DoT rules effective 1 April [60FR50292, 9/28/95] have a
number of new and changed requirements.  Questions ...

172.310 for TI>10, the label category reads "Yellow-III (Muust be
shipped under exclusive use provisions)".  Does this mean that
these words must appear on the Yellow III label?  I would guess
yes since the actual rerquirements that mandate exclusive use
appear elsewhere and 172.310 is just the labeling section.

172.803 required dosimetry for occupationally exposed hazmat
employees if they exceed the 200 TI criteria.  But for fissile
controlled shipments the TI is artificially inflated as a way to
limit the number of packages per shipment.  This then trips the
monitoring requirement despite the fact that the radiation level
is nil.  Is there any way around this, i.e., to avoid having to
needlessly issue dosimeters?

173.457, for shipments with a TI>10, requires meeting 173.441(a)
and (b).  But 441(a) only applies for TI<10.  Am I ,missing
something?  This seems like a null reference.  Even the 441(b)
requirement is moot in regard to the fissile inflated TI
shipments since the actual radiation level is zilch.  The (b)
requirement obviously has meaning for used fuel shipments.  Does
it impact power reactor fresh fuel shipments?

SLABACK@MICF.NIST.GOV  [NBSR Health Physics Group]
    ...a little risk, like a bit of spice, adds flavor to life