Shipping Question

["Roy A. Parker" <70472.711@compuserve.com>]

> Use the conditions and requirements specified in "173.424" for
> Instruments & Articles.
     A disc source does not meet the criteria for an "instrument or
     article.  49 CFR 173.403 defines radioactive instrument and
     articles as meaning
          any manufactured instrument and article such as an
          instrument, clock,  electronic tube  or apparatus,
          or similar  instrument and  article having Class 7
          (radioactive)    material     in    gaseous     or
          non-dispersible solid form as a component part.
     The key term is "component part."  A disc source as was described
     is a stand alone entity and not a component part of anything else.
 
     Further clarification  may be derived from IAEA Safety Series No. 6
     1985 (amended  1990) on  which the  current  U.S.  regulations  are
     based.  Section 418 states in part
          Radioactive material which is enclosed in or forms
          a  component   part  of  an  instrument  or  other
          manufactured article,  with activity not exceeding
          the item and package limits specified in columns 2
          and 3 respectively of Table IV, may be transported
          in an excepted package provided that:
          (a) The radiation level at 10 cm from any point on
              the   external   surface   of   any   unpacked
              instrument or  article  is  not  greater  than
              0.1 mSv/h (10 mrem/h); and
          (b) Each    instrument    or    article    (except
              radioluminescent time-pieces or devices) bears
              the marking "Radioactive."
 
> "SCO" classification is relatively new in the regs and was not
> designed for application to items such as small, low activity, plated
> sources.
     SCO has  been in the international regulations since 1985 and could
     have been  used under the alternate provisions of 49 CFR 171.11 and
     171.12.   Nothing prevents it use in this case, but I agree that it
     is not  best route  to take; nor do I suggest it, since it presents
     more problems than it solves.
 
The best  route is  to ship  the disc  source as  Radioactive  Material,
Excepted Package - Limited Quantity of Material, n.o.s., UN2910.
 
Roy A. Parker, Ph.D.
E-Mail: 70472.711@compuserve.com
Tel: 225-924-1473
Fax: 225-924-4269
------------------------------------------------------------------------
    21-Aug-98 09:34 CDT
From: Ben Poff <BPOFF@ITCRP.COM>
Subject: Shipping Question -Reply
 
Why make things so hard?  Use the conditions and requirements
specified in "173.424" for Instruments & Articles.  Instead of trying to
figure out whether or not "specific activity" and "mass" are issues, one
should read the actual definitions as applicable to the specific
regulations.  "SCO" classification is relatively new in the regs and was
not designed for application to items such as small, low activity, plated
sources.  Everything you need, including package and communication
exemptions, are provided in 173.424.
 
Ben Poff, OHST
Waste Management Specialist
IT Corporation
bpoff@itcrp.com
(505) 262-8948
 

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