Re: Limited Quantity Question

["Alan R. Marchand" <radarm@accessnv.com>]

The inner package or the outer package must be marked "radioactive".
An exception statement must be in the package.
IATA requires declaration on the air bill for air shipments.
The quantity is 10-3 of the A2 or A1 values.
The package must meet the requirements of section 173.410

These are a few items that must be met.

Alan R. Marchand
radarm@accessnv.com

At 10:54 AM 9/5/97 -0500, you wrote:
>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outdated version of 49 CFR, the section dealing with excepted packages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
>
>