Re: Smoke Detectors

[LIPTONW@dteenergy.com]

One caution about shipping smoke detectors, or anything else, as a "limited 
quantity" or "instrument or article" is that you are NOT exempt from the 
hazmat employee training requirements.  Short of training the trash haulers 
and landfill operators, I recommend using the small quantity exception of 49 
CFR 173.4, which does exempt you from the training requirements. 
 
The opinions expressed are strictly mine. 
It's not about dose, it's about trust. 
 
Bill Lipton 
liptonw@dteenergy.com 
 
You wrote: 
 
>C'mon guys  this is a classic Catch 22 situation and I was trying to lay 
>low, but you have dragged me into it. 
  
>1. Yes, NRC  and agreement state regulations say that you may dispose of 
>   the Am-241 smoke detectors in the trash, but how do you get it to the 
>   trash dump.   Classic case of lack of coordination between regulatory 
>   agencies. 
  
>2. Am-241 has  an A2 value of 5.41 mCi.  The Am-241 is a foil, therefore 
>   it is  a solid,  and therefore  the Am-241  limited quantity value is 
>   5.41 uCi.   Thus, it  could easily  be  transported  as  an  excepted 
>   package, which  means the  package  must  meet  the  general  packing 
>   requirement, the  smoke detector  is marked radioactive, the excepted 
>   package notice  is included, and the maximum external radiation level 
>   on the  surface of  the package  is 0.5 mrem/hr.   It  could also  be 
>   considered an  "instrument" and the activity limit in that case would 
>   be 54.1 uCi.   The  same excepted  package criteria  would have to be 
>   met.  But what consumer has been told this?
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