Re: 10 CFR 20.1904(b)

[Robert A Scott <bobscottchp@juno.com>]

	By looking at part (a) of 10 CFR 20.1904 strictly, it speaks only to the
affixing of a label to the container, and describes that label as
containing a symbol and certain words.  Other parts of the container
frequently contain messages which include the words 'Radioactive
Material'.  Clearly, because part (a) speaks only to a label, part (b) is
not referring to anything other than that same label.  

	The original question on this thread requested advise on how to deal
with those other non-label words.  Most of those messages relate to the
character of the container, relative to its qualification for carrying
radioactive material.  When reading statutes and regulations, all
sections should be read 'in pare materia', that is together, rather than
as isolated parts.  Because the purpose of the defacing is to CLEARLY
INDICATE that the empty container is uncontaminated, it is logical that
defacing or removing the label AND other implicating words, even those
not part of the label, is the preferred choice.  It is a small matter to
deface all areas on the container, rather than simply the two labels.

On Fri, 26 Mar 1999 16:08:43 -0600 (CST) "Busby, Bruce"
<bab1303@doh.wa.gov> writes:
>WRT: defacing labels


>  I see no reason for a NRC interpretation. 


	I agree.

Bob Scott, RPO
Roger Williams Medical Center
Providence, RI

>
>---------------------------
>
>20.1904 Labeling containers.
>
>(a) The licensee shall ensure that each container of licensed material
bears a durable, clearly visible label bearing the radiation symbol and
the words "CAUTION, RADIOACTIVE MATERIAL" or "DANGER, RADIOACTIVE
MATERIAL." The label must also provide sufficient information (such as
the radionuclide(s) present, an estimate of the quantity of
radioactivity, the date for which the activity is estimated, radiation
levels, kinds of  materials, and mass enrichment) to permit individuals
handling or using the containers, or working in the vicinity of the
containers, to take precautions to avoid or minimize exposures.
>
>(b) Each licensee shall, prior to removal or disposal of empty 
>uncontaminated containers to unrestricted areas, remove or
>deface the radioactive material label or otherwise clearly indicate 
>that  the container no longer contains radioactive materials.
>
>
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