Re: Shipping question

[William V Lipton <liptonw@dteenergy.com>]

The testing requirements for DOT Type A packages are dispersed through 49
CFR 173, but they're explicit.  See 173.415:  " ... (a) DOT Specification 7A
(paragraph 178.350 of this subchapter) Type A general packaging.  Each
offeror of a Specification 7A package must maintain on file for at least one
year after the latest shipment, and shall provide to DOT on request,
complete documentation of tests ... "  There are 2 key requirements:  (1)
Type A packages must be tested to prove they meet the testing requirements
(described in another part of 49 CFR 173).  (2) Each shipper must have the
test results available.  The second requirement is often misunderstood.  I
ordered Type A packaging from a vendor with a requirement, in the purchase
order, that I be supplied with the required documention.  All that I
received was a "certificate" from the vendor stating that the package passed
the tests.  This is NOT adequate.  I ended up returning the packaging when
the vendor refused to provide the detailed test results.  Another common
misunderstanding is that, by DOT definition (49 CFR 173.403):  "Package
means, for Class 7 (radioactive) materials, the packaging together with its
radioactive contents as presented for transport."  Thus, the shipper must
evaluate the contents against the tests and be sure that the contents are
within the scope of the contents that were tested.  For example, if the test
results are for contents of feathers, the packaging may not be suitable for
lead bricks.  Packaging tested with solids is  not necessarily suitable for
liquids.  Be extremely cautious about adding "scab shielding" to a package.
Unless the package tested included this shielding, the test results may not
be valid.

The opinions expressed are strictly mine.
It's not about dose, it's about trust.

Bill Lipton
liptonw@dteenergy.com

David Gilson wrote:

> I believe the language in 49 is that the package must be "capable" of
> meeting the test criteria.
>
> David Gilson, RRPT
> dgilson@envirocareutah.com
>
> --------
>
> Hi folks,
> Does a type A package actually have to be "tested" to the critieria in
> 49CFR173, or does it just need to be "designed" to meet the test
> criteria?
>
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