Re: RE: Transportation of General Licensed Instrument

[LIPTONW@dteenergy.com]

You are correct as far as it goes.  However, if you ship this as an excepted 
quantity (i.e. "limited quantity" or "instruments and articles") you are
still 
subject to the training requirements of 49 CFR 172, Subpart H (see 49 CFR 
173.422(b)(3).  This requires training AND testing on a variety of subjects.
 
All of this must be documented.  If your facility does not have trained
people 
available, I suggest that you look at shipping this under the "small
quantity 
exceptions" of 49 CFR 173.4.  This exempts you from the training
requirements. 
 This does require package testing, however.   
 
The opinions expressed are strictly mine. 
It's not about dose, it's about trust. 
 
Bill Lipton 
liptonw@dteenergy.com 
 
 
You wrote: 
 
>According to 49 CFR 173.421, you only need a shipping paper if the 
>material (1) is a hazardous substance, or (2) a hazardous waste. Also, 
>under 173.423, if the material meets another DOT hazard class (such as 
>flammable liquid), you have to prepare a shipping paper and note the 
">Limited Quanity Radioactive Material." 
 
>Since the RQ for H-3 is 3.7 TBq (100 Ci), it's not a hazardous 
>substance.  
 
>Since it's an instrument you are (re)using, it's not a waste. 
 
>And unless the H-3 is dissolved in some solvent, it's probably not 
>another hazard class (that's a guess). 
 
>So, based on the information given, you do not need a shipping paper. 
>You do need the notice specified in 49 CFR 173.422, which can be on the 
>package itself or on a separate document, probably the phrase in 
>173.422(a)(2). 
 
>As a responder, I personally prefer the notice available separately, 
>away from the package, so it can be reviewed at a safe distance, should 
>an accident or incident occur. 
 
^^^^^^^^^^^^^^^^^^^^^^^^^^^ 
>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 
 
 
 
 
> -----Original Message----- 
> From:	Mr Jo [SMTP:mjo@scs.unr.edu] 
> Sent:	Monday, May 10, 1999 16:54 
> To:	Multiple recipients of list 
> Subject:	Transportation of General Licensed Instrument 
>  
> We need to transport our EC Detector (which contains 300 mCi H-3) to 
> Pennsylvania 
> to use it there for two weeks and bring it back. This EC is a general 
> licensed 
> item. 
>  
> I am preparing a shipping document as an excepted package UN2910. We 
> plan to use 
> our own personnel and a rental vehicle to transport. 
>  
> Does this type of shipment require shipping documents? Thanks. M. Jo 
> ======================================================== 
> Myung Chul Jo, MS, CHP 
> EH&S, Mail Stop 328 
> University of Nevada, Reno 
> Reno, Nevada 89557 
> (702)784-4540 
> (702)784-4553 fax 
> mjo@scs.unr.edu 
> 
************************************************************************
The RADSAFE Frequently Asked Questions list, archives and subscription
information can be accessed at http://www.ehs.uiuc.edu/~rad/radsafe.html