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LSA-1 rule
An interesting note (glitch?) with regard to
the new DoT rules. We were interested in shipping
some triated water that met the LSA-1 requirements.
The USDOT reg has the provision for 'activated
materials' in the LSA-1 definition. [Note that this
provision is not currently in the IAEA rules so
that an international shipment is not permitted.]
Table 8 even has an entry for LSA-1 liquids and
specifies an IP-1 package.
173.427(c)(2) restricts LSA-1 liquids to specific
specification packages, but IP-1 is included by
indirect reference via another paragraph.
BUT .....
It turns out that they were thinking of SOLID
acivated materials when this provision was added.
So despite a simple (simplistic?) reading of the
rule, what is said is not what is intended.
[One can hope that further analysis will allow
what was not thought of, but for now it is
forbotten.] Onwards to LSA-II/IP-2......
Much assistance for our valuable resource at DoT
was needed to figure this all out. I suspect that
more such glitches will show up. I hope others
will share them.
A little risk adds spice to life.
slaback@MICF.NIST.gov