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Re: RAM Shipping Question
The "shipper" may also be the "carrier". However, the driver must meet the
training requirements of 49 CFR 172, Subpart H ("Hazmat Employee Training").
For "limited quantity" shipments, other requirements include (see 49 CFR
173.421):
quantity limits
package must meet general design requirements of 49 CFR 173.410
dose rate and contamination limits on package
"Radioactive" marking
no more than 15 grams of U-235 (This may be a problem if shipping natural or
depleted uranium, e.g., 5 pounds of natural uranium would contain more than 15
grams of U-235.)
shipping papers if the material is a hazardous substance (i.e., greater than
RQ) or a hazardous waste
"limited quantity" notice of 49 CFR 173.422
Other than that, I don't see any problems!
The opinions expressed are strictly mine.
Here's to a risk free world, and other fantasies.
Bill Lipton
liptonw@detroitedison.com
This may be a stupid question for those in the shipping biz, but it's been
bugging me for a while. Can a person put a package of properly packaged (in
this case limited quantity) RAM in a Personnally Owned Vehicle and "ship" it
to its destination? If not, what provision of the DOT regs prohibit this?
I can't find anything that specifically states that a 'carrier' has to be a
"for profit" entity that is separate from the 'owner' of the material. Are
there any requirements that 'shippers' of RAM have to have some particular
certification in HAZMAT transport? Does it matter if the material is not
licensed by NRC? We are a DOE site. Are there any DOE rules that say this
can't be done? The person doing the transport would be a representative of
the owner of the material.
Keith Welch
Thomas Jefferson National Accelerator Facility
Newport News VA
welch@cebaf.gov
Ph: (757)269-7212
FAX:(757)269-5048