Wheeled transport vs by foot

["Edwards, Ben E" <bee6783@glaxowellcome.com>]

Radsafers,

I've heard both views:

1) any Hazardous Material that moves "in commerce" over a public roadway is
regulated by DOT, regardless of whether it's by truck, bicycle, dogsled,
jogger, shopping cart, etc.; mode of conveyance is irrelevant in determining
whether or not DOT applies.

2) you can walk across/along a public road with your institution's RAM [i.e.
"in commerce"] in your backpack and it's not regulated by DOT because no
"vehicle" is involved [this has been touted by some as a way to move RAM
locally without the heartache & pain of DOT compliance].

What do you think?

Ben Edwards
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