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Re: Isotope Transfer Documentation Requirements



In this case it appears that a "Shippers Certification" may not be required.
Check 49CFR172.204(b) Exceptions

"...no certification is required for a hazardous materials offered for
transportation by motor vehicle and transported: ... 

(ii) By the shipper as a private carrier except for a hazardous material
that is to be reshipped or transferred from one carrier to another."





At 09:01 AM 12/30/97 -0600, you wrote:
>Radsafers,
>
>We're looking for a way to legally yet simply transfer radioactive material
>between our facility and an adjacent but separately licensed facility.  We
>- the Medical College of Georgia - are licensed by the State; they - the
>Augusta Veterans Administration Hospital - are licensed by the NRC. 
>The facilities are physically connected and we, by contract, supply rad
>safety services to the VA.   For example, frequently it would be
>convenient to count a source in one facility for use in the other.  Since
>the material always remains within the confines of one or the other
>facilities, we may not have to comply with DOT regulations.  If anyone
>has come up with a simple way to comply with rad mat transfer
>requirements for a similar situation, we'd very much appreciate hearing
>from you.
>
>Reply to:
>
>Bill Stephany
>Assistant RSO
>Medical College of Georgia
>fiss.bstephan@mail.mcg.edu 
>
>
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Tad  Blanchard            /__ \ /___\   NASA-Goddard Space Flight Center
Nat'l Health Svc, Inc          O         Code 205.9, Greenbelt, MD 20771
Sr Health Physics Tech        / \                    Phone: 301-286-9157
Assistant RSO                /___\                   Fax:   301-286-1618
                 mailto:Tad.M.Blanchard.1@GSFC.NASA.gov
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