Re: Shipping

[LIPTONW@detroitedison.com]

You wrote:  
  
The way I interpt the regs for limited quanity shipment of radioactive 
material is since limited quanity is excepted from shipping papers 
(49CFR173.424) that driver training is not require IAW 49CFR172.606. 
 
Is there anything else that contradict this statement. 
 
Thanks 
--  
<><><><><><><><><><><><><><><><><><><><><><><><><><><><><><><><><><><> 
Steven L. McQueary, NRRPT	mcqueary@lamar.colostate.edu 
Colorado State University	Phone: (970) 491-3928 
Radiation Control Office	Fax:   (970) 491-4804 
<><><><><><><><><><><><><><><><><><><><><><><><><><><><><><><><><><><> 
 
Is this "limited quantity" or "instruments and articles" - 49CFR173.424 is
for 
instruments and articles, while 49CRR173.421 is for limited quanitity.  It 
doesn't make any difference for your question, however, since both
regulations 
include the statement:  "The material is otherwise prepared for shipment as 
specified in accordance with 49CFR173.422."  49CFR173.422(b) includes the 
statement:  "An excepted package of Class 7 (radioactive) material that is 
classed as Class 7 and is prepared for shipment under the provisions of 
49CFR173.421, 423, 424, ... is not subject to the requirements of this 
subchapter except for - ...(3) The training requirements of subpart H of
part 
172 of this subchapter ..."  Thus, persons handling a limited quantity 
shipment, including the driver, would require "Hazmat Employee Training". 
The 
only way I could see of avoiding the training requirement would be if the 
material could be shipped under 49CFR173.4, "Small quantity exceptions". 
This 
is very limiting, however, and also requires package testing.    
 
The opinions expressed are strictly mine. 
It's not about dose, it's about trust. 
 
Bill Lipton 
liptonw@detroitedison.com