DOT regulations, Specific Activity

["John McCormick" <J_McCormick_Bionomics@classic.msn.com>]

There is confusion over the DOT definition of radioactive material.  Some 
hazardous waste disposal companies are telling clients that if it is below 
.002 uCi/ml then it does not require manifesting and they can dispose of it as 
hazardous or non-radioactive waste.  This is erroneous.

A radioactive material that is less than .002 uCi/gm before packaging may be 
defined as non-radioactive under DOT regulations.  However, if the material is 
a waste it must be sent to a licensed facility for disposal and the isotope 
and activity provided to the receiving facility.  

Scintillation and Animal Carcasses containing H-3 and/or C-14 below .05 uCi/gm 
are exempt under NRC and most state regulations.  As such they are not defined 
as radioactive materials and can be shipped as such.  The .002 uCi/gm DOT 
definition does not apply.

John McCormick