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Re: RAM Shipping Question
The controlling regulation appears to be 49 CFR 173.422(b), which states
that "[a]n excepted package of
Class 7 (Radioactive) material that is classed as Class 7 and is prepared
for shipment under the provisions of 173.421, 173.423, 173.424, 173.426 or
173.428 is not subject to the requirements of this subchapter
except for-
(1) Sections ... 177.861 [of course, there is no longer a section 177.861];
(2) ...;
(3) The training requirements of subpart H of Part 172 of this subchapter
and ..."
The exemption from the provisions of Sub Chapter C (Hazardous Materials
Regulations) appears to relieve you from all of Parts 171 - 180, except as
noted above. The section 177.861, if it existed, would probably
require you to report any "incidents" or "decontamination".
Does anyone else have trouble following when you're in a subpart, a
subchapter, a subtitle .... The Feds
could work a bit a some catchier names than "C" and "49", not to mention
their prose style [e.g., "Class 7 material ... classed as Class 7"]
Hope this helps, Don
Don Jordan
The University of Chicago
Office of Radiation Safety
Zoology Building Room 11
1101 East 57th Street
Chicago, Illinois 60615
Tel. 773-702-6299
Fax 773-702-4008
email Don_Jordan@fpm.uchicago.edu