RE: Transport Issues

[Bruce Bugg <BRUCEB@psc.state.ga.us>]

Also, note that although a container is empty, placarding of a vehicle
>might still be required (at least the way I read the reg).   I would
>think it's somewhat unusual to have to placard a vehicle for an empty
>container, but I don't think it's impossible. 

No, It's not impossible, but I think it's unlikely. You'd have to have
enough residual contamination that the packages emit enough external
radiation to require Yellow-III labels.

>>One gripe of mine, however, is that with radioactive substances, one
>> placard covers all situations.  We know that the risks can vary
>> enormously, depending on the material and quantity.  This is of
special
>> concern to the emergency services who first respond to an accident.
>> Perhaps this is an area where radiation experts can work with the DOT
to
>> divide the radiation placards into categories, much like what is done
>> for explosives.

I guess I could argue that there are three placards: (1) None required,
(2) the "standard" radioactive placard, and (3) the square background
requried for highway route controlled quantity.

It is a little silly. A tractor-trailer with 40,000 lbs. of White-I and
Yellow-II labeled boxes needs no placards. A single Yellow-III labeled
box in the saddle bags of a motorcycle, and you've got to figure out
where to mount the things. 

In order to change the placarding situation, you'd have to convince DOT,
and then OMB, that the benefits of change outweigh the costs. Having
dealt with DOT, I doubt the data exists to do that (Accident data? There
practically is none for Class 7), much less any institutional desire to
do that.

Plus, the regulated industry would scream. Imagine all the medical
couriers that suddently need CDL and all their vehicles that now have to
comply with the Motor Carrier regs. Again, given the accident history, I
wonder about the possibility of making that case.

^^^^^^^^^^^^^^^^^^^^^^^^^^^
Capt. Bruce Bugg
HazMat Specialist - Enforcement Officer
Ga. Public Service Commission
1007 Virginia Avenue, Suite 310
Hapeville, GA  30354-1325
voice:	404.559.6627
fax: 	404.559.4972
e-mail:	bruceb@psc.state.ga.us
or:	75720.1177@compuserve.com


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