Re: Transportation

[LIPTONW@detroitedison.com]

It depends on the testing company's license.  A DOT shipper has to legally 
"possess" the material he's shipping.  Hence, if the testing company is to 
assume responsibility for shipping a source from the customer's facility, the 
testing company's license must allow it to possess the source at a remote 
site.  Many companies have such provisions in their licenses.  Insist on 
reading the license, however.  These provisions may have conditions.  For 
example, there may be quantity limits that apply to all material possessed by 
the licensee.  Be sure that the testing company is in compliance with all 
conditions before transferring possession.  Some agreement state licenses can 
be complex.  If the testing company's license restricts licensed activities to 
a specific site, then you must fulfill the responsibility of transporting the 
source to that site. 
 
The opinions expressed are strictly mine. 
Here's to a risk free world, and other fantasies. 
Bill Lipton 
liptonw@detroitedison.com

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• To: Multiple,recipients,of,list,radsafe@romulus.ehs.uiuc.edu
• Subject: Transportation
• From: "radsafe@romulus.ehs.uiuc.edu" <radsafe@romulus.ehs.uiuc.edu>
• Date: 06 Feb 97 10:34:28
• Reply-to: radsafe@romulus.ehs.uiuc.edu

     Previously there was a thread on the BB concerning transportation of 
     radioactive materials.  When a source (neutron source) is accepted by 
     a company for testing, packaging and shipping can that company accept 
     the source on its NRC license, and then assume the liability for 
     transport?  Or does the source remain on the license of the primary 
     owner until received by a new owner and not be on the shipping 
     company's license?  The CFRs address that under an NRC licensee (has 
     the) "... right to receive, acquire, own and possess..." Who has the 
     liability?
     
     Thanks in advance, 
     Mike Barringer
     mike_barringer@fernald.gov

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