RE: RAM Shipping Question

["Edwards, Richard W" <Richard.Edwards@PSS.Boeing.com>]

§ 177.804  Compliance with Federal Motor Carrier Safety
           Regulations.

  Motor carriers and other persons subject to this part shall comply
with 49 CFR Parts 390 through 397 (excluding §§ 397.3 and 397.9) to the
extent those regulations apply.

§ 177.816  Driver training.

  (a)  In addition to the training requirements of § 177.800, no carrier
may transport, or cause to be transported, a hazardous material unless
each hazmat employee who will operate a motor vehicle has been trained
in the applicable requirements of 49 CFR parts 390 through 397 and the
procedures necessary for the safe operation of that motor vehicle.
Driver training shall include the following subjects:
  (1)  Pre-trip safety inspection;
  (2)  Use of vehicle controls and equipment, including operation of
emergency equipment;
  (3)  Operation of vehicle, including turning, backing, braking,
parking, handling, and vehicle characteristics including those that
affect vehicle stability, such as effects of braking and curves, effects
of speed on vehicle control, dangers associated with maneuvering through
curves, dangers associated with weather or road conditions that a driver
may experience (e.g., blizzards, mountainous terrain, high winds), and
high center of gravity;
  (4)  Procedures for maneuvering tunnels, bridges, and railroad
crossings;
  (5)  Requirements pertaining to attendance of vehicles, parking,
smoking, routing, and incident reporting; and
  (6)  Loading and unloading of materials, including-
  (i)  Compatibility and segregation of cargo in a mixed load;
  (ii)  Package handling methods; and
  (iii)  Load securement.
  (b)  Specialized requirements for cargo tanks and portable tanks
[removed as not applicable to this discussion]
  (c)  The training required by paragraphs (a) and (b) of this section
may be satisfied by compliance with the current requirements for a
Commercial Driver's License (CDL) with a tank vehicle or hazardous
materials endorsement.
  (d)  Training required by paragraph (b) of this section must conform
to the requirements of § 172.704 of this subchapter with respect to
frequency and recordkeeping.

§ 177.834  General requirements.

  (a)  Packages secured in a vehicle.  Any tank, barrel, drum, cylinder,
or other packaging, not permanently attached to a motor vehicle, which
contains any Class 3 (flammable liquid), Class 2 (gases), Class 8
(corrosive), Division 6.1 (poisonous), or Class 7 (radioactive) material
must be secured against movement within the vehicle on which it is being
transported, under conditions normally incident to transportation.
  (b)  (Removed and Reserved).
  (c)  No smoking while loading or unloading.  Smoking on or about any
motor vehicle wile 
..etc.

And then there's all the things brought up in Parts 390 through 397.
And, as has already been mentioned, the liability issue.

Not worth it. Particularly with fines up to some incredible amount
($25,000?) for every violation of the regulations...not just every
event.

Rick Edwards, Analyst

The Boeing Company, Radiation Protection Technical Services Group
(425) 393-8250
>