Re: Monitoring of UN2910 Packages and receipt of contaminated packages

["Tom Johnson" <tjohnson@radtrain.com>]

Here is some transportation info you may want to look at. I would NOT advise
going by what I say, rather, I suggest that you look at the CFR's yourself,
since there may be details which I am not aware of, but here are the
references that I would recommend looking at to start:

In 49 CFR 172.101 table (p 290 in my regs dated April 98), column 4
indicates that UN2190 applies to excepted packages - limited quantities.
Since by definition this is less than a type A quantity, it would seem that
mandatory receipt inspection does not apply to UN2190 packages, unless
leaking, damage to integrity, or other conditions as listed in 20 CFR
20.1906(b)(3).

As for receiving contaminated packages, you may want to look at 49 CFR
173.443.a.2, if you are using detection techniques which you KNOW to be more
efficient than the sender of the package used. I call it the "ten times
rule", and I recommend that you read the DOT/NRC position statement on it if
you get contaminated packages. I have an electronic copy, and I will send it
to all who desire a copy, but it is also available from the NRC (or maybe
DOT?) positions database.  The DOT (49CFR) does not concentrate on receipt -
this is more of an NRC issue, since the package is no longer actively being
transported.

Other federal regulations may apply, but I am unsure of those.

Just my opinion,
Tom Johnson

PS: If you want a copy of the electronic position statement, PLEASE email me
privately at
tjohnson@radtrain.com
ask me for the ten times rule.