Shipping tritium exit signs

["Radiological Health Unit" <raldrich@emi.com>]

Please stop me before I hurt myself! 

I'm attempting to understand the requirements of 49CFR as they relate  to
the shipment of tritium exits signs: 

Tritium exit signs can be shipped under the excepted packages for 
instruments and articles provisions of 49CFR173.424. Assume the activity
limits per device and per package, and the contamination limits are all
met. There is no uranium-235 and obviously no external radiation levels. 

It looks to me as though the only requirements for the packaging is that it
meet the general design requirements of 173.410. Is this correct?

The only shipping paper requirement is that a notice be placed inside the
package certifying that it conforms to 173.424. Is this correct?

Now by my reading of 173.410, and comparison with the testing requirements
of ANSI N540 "Classification of Radioactive Self-Luminous Light Sources",
any tritium exit sign that has been manufactured and tested in accordance
with ANSI N540 can be considered as meeting the general design requirements
all by itself. The cardboard box the sign is placed in can be considered as
just an overpack. Is this correct?

Is there any  requirement that the shipper document that a package meets
the general design requirements of 173.410 if he/she is shipping something
as an excepted package? If so where is this found in the code?

These questions (and answers) bear directly upon the issue of what persons
who obtain these devices under GL are supposed to do when its time to
replace or dispose of them. The manufacturer can send a box with the notice
of certification to put inside, but that's about it. It is absurd to
require that such persons retain documentation of package testing. To do so
would only further encourage surreptitious dumping in the trash.

Any edifying comments would be appreciated. Please respond to me directly
as I am on the digest plan and have a somewhat of a reading backlog.


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Clayton Bradt <raldrich@emi.com>        phone: 518/457-1202
Assoc. Radiophysicist                         fax:      518/457-5545
NYS Dept. of Labor
Radiological Health Unit
Blg.12, Rm 134A
State Office Campus
Albany, NY 12240
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