Re: DOT training re: limited quant.

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

The 49 CFR requires general and specific training for any part of the
regulation. 173.400 section refers to radioactive shipments. Training is
one part that is required for even Radioactive Material-excepted packages.
General knowledge is required to know if the amount is regulated or not. A
driver for excepted package amounts should have the general training but
does not require a special drivers licence. Only placarded amounts (LSA/SCO
or Yellow III) requires a hazmat drivers licence. The next area is if you
have a Radioactive Material-excepted package amount, does the shipment meet
any other hazard class in the 49 CFR? The other hazard class will become
the primary hazard. Also, if the sample is liquid, the proper amount of
absorbent material must be used. There are still some more requirements to
meet like the exemption statement, package requirements of 173.410 and
radioactive markings to be meet.
As you can see, even with excepted package amounts of radioactive material,
you must know the regs to use the regs.


Alan R. Marchand
Las Vegas, NV
radarm@accessnv.com 

At 03:26 PM 11/19/97 -0600, you wrote:
>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
>-----------------------------------------------------------
>Lester.Slaback@nist.gov
>-----------------------------------------------------------
>
>
>