Re[2]: Limited Quantity Question

[D_S_Steve_Gunnink@RL.gov]

 Good day,
 
 You should also consider the options presented to you in 49 CFR 
 173.422.(a)  A "notice" must be enclosed in or on the package, 
 included with the packing list, or otherwise forwarded with the 
 package.
 
 There are some options, and there are companies that include the 
 required "notice" on the shipping paper.
 
 Even with a limited quantity shipment, you should still check the 
 papers.  They might tell you what you want to know.
 
 Steve Gunnink
 Fluor Daniel Hanford Co
 RadCon Technical Services
 (509) 372-2842
 d_s_steve_gunnink@rl.gov
 The opinions expressed here are my own.


______________________________ Reply Separator _________________________________
Subject: Re: Limited Quantity Question
Author:  "Norman Randy" <rnorman@smtplink.microbio.com> at -MailLink
Date:    9/5/97 11:48 AM


     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.
 
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Subject: Re: Limited Quantity Question
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