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Re: Limited Quantity Question
I'm afraid you're missing nothing! Nobody said regulations had to make
sense. It's obvious that the only way the transporter and responders
could tell that radioactive materials were involved is if the inner
package and it's required "Radioactive" marking become visible.
My guess is that they figure the quantities are small enough that
folks needn't worry unless the situation is such that one gets close
enough to see the "radioactive" marking on the inner package
(173.421(a)(4)). That is, it's not enough to worry about knowing of if
you have to meet with the HazMat team before going in (and can be
safely dealt with upon unexpected discovery), and generally not a
problem unless the outer package comes open in a manner that reveals
the "Radioactive" marking. Plus I expect they'd never let it reach the
point where they didn't require one to deal with known contamination,
even when the potential magnitude of said contamination is small.
Just some thoughts. I suppose it's rather dangerous to try to read the
regulators' minds, but...
Randy Norman
Safety Manager & RSO
MA BioServices, Inc.
Rockville, MD
My own considered opinions and not necessarily those of my employer.