DOT Regulations

["Roy A. Parker" <70472.711@CompuServe.COM>]

> The DOT regulations had an exemption for physicians transporting
> radioactive material, as I recall.  Does this exemption still exist?
> If so, can someone please cite the 49CFR.
     The DOT Tile 49 regulations never had this exemption.  The
     exemption you are thinking about is the NRC and agreement state
     regulations.
          10 CFR 71.9 Exemption of physicians.
 
             Any physician licensed by a State of the United States
          to dispense drugs in the practice of medicine is exempt
          from Section 71.5 with respect to transport by the
          physician of licensed material for use in the practice of
          medicine. However, any physician operating under this
          exemption must be licensed under 10 CFR part 35.
 
     Since this is not in Title 49 (DOT Regulations) and with the
     Uniform Hazardous Material Transportation Safety Act and it
     adoption by states and/or the changes in definition of intrastate
     commerce, the validity of this exemption may be questionable.
 
> Also, if a limited quantity of radioactive material is packaged
> according to 49 CFR 173.421 (requirements for excepted packages) can
> the material be transported in a private vehicle, taxicab, city bus,
> subway train, etc.?  My reading says that excepted material is exempt
> from any restrictions on the type of vehicle.
 
     An individual is a private carrier who transports in a private
     vehicle and is subject to the 49 CFR 177 modal requirements as is
     the transport in a taxicab, city bus, and subway train.
     49 CFR 177.870(g) Regulations for Passenger Carrying Vehicles Is
     Applicable, but applies only to passenger carrying vehicles for
     hire.  Therefore, there are no restrictions pertaining to excepted
     packages.  Note, if mailing a package the limited quantity is 10%
     of the applicable 49 CFR 173.425 values.
 
Roy A. Parker, Ph.D.
Radiation Physics Consultant to
Federal Express Corporation
70472.711@compuserve.com
504-924-1473