49 CFR 173.441(b)(4)

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

Keep in  mind that  49 CFR 173.441(b) which pertains to the 2 mrem/hr in
any normally  occupied space is only applicable when transporting one or
more packages  which exceed  200 mrem/hr at  the surface  of the package
and/or exceed  a transport  index (TI)  of 10.  Otherwise the separation
distance rules prevail.
 
Roy A. Parker, Ph.D.
E-Mail: 70472.711@compuserve.com
Tel: 225-924-1473
Fax: 225-924-4269e
-------------( Forwarded computer archived letter follows )-------------
    10-Sep-98 09:51 CDT
From: LIPTONW@dteenergy.com
Subject: items of interest to shippers
 
Two notices in today's (9/10/98) "Federal Register" should be reviewed
by hazmat shippers:
 
(1) (pages 48566 - 48569) DOT is withdrawing its requirement for a
"Radiation Protection Program", as specified in 49 CFR 172, Subpart I.
This was expected.  However, this notice also includes a change to 49
CFR 173.441, the section on dose rate limits.  This section includes a
limit of 2 mrem/hr in any normally occupied space, i.e., the truck cab.
The exception to this limit had been limited to private carriers where
exposed personnel wear dosimetry as part of a radiation protection
program.  The new wording makes this exception applicable to all
carriers.
 
(2) (page 48544) DOT is requesting comments on its "Emergency Response
Guidebook", for incorporation in the next edition.  Now's your chance;
don't stay silent now and complain later.
 
The opinions expressed are strictly mine.
It's not about dose, it's about trust.
 
Bill Lipton
liptonw@dteenergy.com
 

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