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Re: Scope of DOT Regulation

To: radsafe@romulus.ehs.uiuc.edu
Subject: Re: Scope of DOT Regulation
From: Keith Welch <welch@CEBAF.GOV>
Date: Wed, 06 Nov 1996 08:45:03 -0500 (EST)
Date-Warning: Date header was inserted by CEBAF.GOV

At 09:33 AM 11/5/96 -0600, you wrote:
>I believe that the operative factor is "commerce".
>
>Are you engaged in commerce ?
>
>No commerce = No subjection to 49 CFR (per 49 CFR 171.1)
>
>Bill Pitchford

Folks with direct experience here might correct me, but the training I've
had has led me to believe that "commerce" is very broadly defined when it
comes to hazmat shipping.  I'd be very cautious about shipping RAM under a
"non-commerce" exception.

Keith Welch
Thomas Jefferson National Accelerator Facility
Newport News VA
welch@cebaf.gov

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