Hand Carries

[George Cicotte <GCICOTTE@GW.ODH.STATE.OH.US>]

DOT regulations (49 CFR) apply to carriage by rail, ship, motor transport,
etc., over public highways.  NRC regulations apply to NRC licensees. 
Look at 10 CFR 71.5, which states in part:

"Each licensee who transports licensed material outside the site of
usage, as specified in the NRC license, or where trnasport is on public
highways, or who delivers licensed material to a carrier for transport,
shall comply with the applicable requirements of the DOT regulations in
49 CFR . . . "

Transfers of materials from one facility to another on the same license
are controlled by license condition.  Typically this means a strong, tight
container, irrespective of DOT.  I say typically, because it is based on the
requirement to control radioactive materials.  If you hand carry
something, or if it doesn't go over public highway and the public is not
exposed, you are governed by license conditions such as occupational
exposure, workplace contamination, etc.

Respectfully,

George R. Cicotte
Health Physicist III
Ohio Dept. of Health, Bureau of Radiation Protection
Nuclear Material Safety Section
gcicotte@gw.odh.state.oh.us

DISCLAIMER:  The Governor and I don't agree on everything, and this
may be one of those times. . . unofficial unless notified otherwise.