I-125 Limited Qty RQ

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

Jim,
 
This one is a total nightmare.
 
Regulations state  that  an  excepted  package  -  limited  quantity  of
material which  is also  a hazardous  substance (RQ)  is  excepted  from
specification packaging, marking, and labeling.
 
Shipping  paper   is  required,   except  the   additional   descriptive
information for  radioactive materials is not required.  This means that
the shipping paper descriptive information would consists totally of:
 
    RQ, Radioactive Material, Excepted Package - Limited Quantity of
                            Material, UN2910
 
Certification is  required, except  for the  certification  that  it  is
radioactive material  intended for  research, or  medical  diagnosis  or
treatment.
 
The problem is that on the carrier side no one is trained to these "fine
tuned" exceptions  and variations.   This  is the  only case that I know
where these types of exceptions and variations occur.
 
Problem 1: Carrier   personnel    are   trained    that   the   shipping
           paper/declaration  must   be  consistent  with  the  packing,
           marking and  labeling.   In this  case there  is  a  shipping
           paper, but  no specification  packaging requirements, marking
           or labeling.   This is almost guaranteed to cause the package
           to be bumped.
 
Problem 2: Carrier personnel  are trained  to check  for completeness of
           the  shipping   paper/declaration.    Since  the  radioactive
           material additional  descriptive information  is not required
           it  would   appear  to   most  carrier   personnel  that  the
           shipping/declaration  is   incomplete.     This   is   almost
           guaranteed to cause the package to be bumped.
 
Problem 3: All radioactive material, excepted package - limited quantity
           of material,  UN2910 shipments  may go on passenger aircraft.
           Carrier   personnel    are   trained    to   look   for   the
           "research/medical" certification  statement.  If the shipment
           is not for "industrial" purposes then one may not submit such
           a statement.    Catch  22.    An  excepted  package  must  be
           classified for passenger aircraft, but the "research/medical"
           statement can not be submitted.  This is almost guaranteed to
           cause the package to be bumped.
 
I do not have a very good solution to these dilemmas.  The best one (and
this is not very good) that I can come up with is to:
 
(1) mark the package:
 
          RQ Radioactive Material, Excepted Package - Limited
          Quantity of Material, UN2910
 
          Excepted Package
 
(2) label the package with White I labels
 
(3) complete the  shipping paper/declaration  with the usual radioactive
    material descriptive information
 
(4) certify it for passenger aircraft by
 
          I hereby certify that this shipment is radioactive
          material, excepted package - limited quantity of
          material, UN2910 which may be transported on
          passenger aircraft pursuant to 49 CFR 175.700(c).
 
There is  no guarantee  that the above "fix" will work.  I only maintain
that it  is legal  and stands a better chance of getting through because
of the type of training that carrier personnel receive.
 
I know that the major radioactive material suppliers have addressed this
problem by  simply  shipping  this  type  of  commodity  as  Radioactive
Material, n.o.s.,  UN2982 in  a DOT 7A  Type A package.  Since they have
Type A  packages it  is easy  for them.   I  can see where an occasional
shipper would have problems.
 
The more  satisfying solutions  would be  (1) relief  from DOT  and  (2)
better training of carrier personnel.  Concerning relief from DOT I have
discussed this  with them in the past, but it has not seemed to be a big
problem.   I will  forward this  e-mail to  DOT and  bring up  the issue
again.  If this is a potential issue with you I also urge you to contact
DOT.  Better training of carrier personnel sounds easy, but consider the
rarity of this issue, the number of packages to be checked daily and the
difficulty of  maintaining proficiency  of this issue among a very large
number of  personnel.   Unfortunately the  more time it takes to check a
package is reflected in your cost of shipping.
 
 
Roy A. Parker, Ph.D.
Radiation Physics Consultant to
Federal Express Corporation
Tel: 225-924-1473 - Note new area code
Fax: 225-924-4269 - Note new area code
(New area code not working yet in some areas.  Try old 504 area code.)
-------------( Forwarded computer archived letter follows )-------------
    02-Oct-98 11:07 CDT
From: Jim Tracy <james.tracy@nist.gov>
To: Multiple recipients of list <radsafe@romulus.ehs.uiuc.edu>
Subject: Shipping I-125 as limited quantity, RQ
 
How does one handle shipping a limited quantity of radioactive material
that is also an RQ?  With a Type A package I normally mark RQ  on the
package and shippers declaration in association with the proper shipping
name.  Where do I need to mark RQ with a limited quantity package?  I
generally enclose the "this package conforms to ..." notice in the
package.
 
Note:  I'm quite familiar with shipping radioactive material so I don't
need any responses on that aspect, just the RQ aspect.
 
I'm shipping a solid source containing 1 x 10E-3 TBq of I-125
 
The A2 value is 2 TBq
The derived limited quantity limit is 2 x 10E-3 TBq, thus I meet the
limited quantity limit
 
The RQ value is 3.7 x 10E-4 TBq, my activity exceeds this.
 
 
Jim Tracy
NIST
301-975-5800
James.Tracy@nist.gov
 

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