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Re[2]: RAM shipment
There's no conflict, you just have to read the complete reg. 173.4(b)
addresses the additional RAM requirements. This is limited quantity
stuff we're talking about. Just put it in a good box, add the
disclaimer and put it in the trunk. The whole point of limited
shipments is that the disclaimer goes inside the box so that it
doesn't upset anyone who might notice "radioactive".
Greg Krause
North Dakota Radiation Control Program
e-mail: ccmail.gkrause@ranch.state.nd.us
______________________________ Reply Separator _________________________________
Subject: Re: RAM shipment
Author: RADSAFE (SMTPMAIL.RADSAFE) at ~GATEWAY
Date: 7/14/97 10:23 AM
There is obviously a conflict between the two regs, 173.4 and 173.422,
which, I suppose, is what judges get paid to resolve. One might argue that
173.422 only applies to limited quantity packages which _do not_ also meet
the standards of 173.4.
Thanks for pointing 173.4 out to me. I only look at it when I have to ship
a package that also contains
an additional hazard.
Don
At 06:31 PM 7/11/97 -0500, you wrote:
>It is interesting that 49 CFR 173.4 "small quantities of ...Class 7
>materials... are not subject to any other requirements of this subchapter
>if--
>Small quantities are defined in 173.49(a)( iv) as levels specified in
>173.421, 424, 425, and 426.
>
>The subchapter referenced is Subchapter C Hazardous Material
>Regulations. It basically says that if you follow the specific requirements
>of 173.4 then there are no other requirements under the hazmat regs.
>
>
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