Limited Quantity Question

[Keith Welch <welch@CEBAF.GOV>]

I'm confused about some apparently conflicting requirements in the
transportation regs.  Maybe someone can straighten me out.  In my slightly
outdated version of 49 CFR, the section dealing with excepted packages
says, among other things: (173.421(a)) the package is excepted from "...
specification packaging, marking .... shipping paper and certification
requiements..."  when the criteria specified are met.  In addition, in
173.422(b) it states that an excepted package is "...not subject to the
requirements of this subchapter except for..." (certain sections dealing
with incident reporting and contamination control in case of accidents).
Now, it would seem pretty clear that we don't have to worry about any
mention of radioactive material on the shipping papers from the above two
exception statements.  But, in Subpart C (shipping papers), 172.203(b) says
limited quantity shipments have to have "limited quantity" on the shipping
paper.  I've finally realized that this is not required for RAM (because of
the exception in 173.421) but non-RAM hazmat normally requires it.

Now, I'm going to try to use a little common sense (I know, bad idea) and
pose a question.  The only parts of the subchapter specifically mentioned
that must be met are the ones regarding incident reporting and
decontamination: (173.422(b) refers you to 171.15, 171.16, 174.750, etc.).
Here's the common sense question:
If there is an incident or accident involving radioactive material in a
limited quantity shipment, how in the world would the shipper know there
might be a contamination problem if there is nothing on the shipping papers
indicating the presence of RAM?  If the packages are badly damaged, you
might happen to find a "radioactive" label in the mess, but otherwise
there's no way to know for sure.
The DOT took pains to ensure that this section of the rule was NOT excepted
in the case of limited quantity RAM, but I can't see how one can reasonably
expect it to be met given the usual methods of packaging Ltd qty RAM.
What am I missing?

Keith Welch
Thomas Jefferson National Accelerator Facility
Newport News VA
welch@cebaf.gov
Ph: (757)269-7212
FAX:(757)269-5048