DoT training re: limited quant.

[Lester.Slaback@nist.gov]

49CFR requires drivers of vehicles transporting hazardous
materials to have certain training and to carry documentation of that.  Is
anyone aware of a waiver/exception to that for
the transport of limited quantity packages?

Clearly if a research sample is less than 2 nCi/g the question  is moot. 
The sample is not hazardous material.

But we (and I suspect others) have cases where the amount of
activity is truly miniscule, but >2 nCi/g, where the researcher would like
to transport the object via personal vehicle back to their parent
organization. [Note: Please don't repeat the previous discussion on
insurance risk.  That has been covered.] Is the training requirement
applicable?
My reading is YES, but one is always hopeful for a more rational
interpretation.

-- 
the above are the personal musing of the author,
and do not represent any past, current, or future
position of NIST, the U.S. Government, or anyone else
who might think that they are in a position of authority.
NBSR Health Physics
NIST
Gaithersburg, MD 20899
301 975-5810
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Lester.Slaback@nist.gov
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