Re: Shipping Question

[Quang Le <quangle@SLAC.Stanford.EDU>]

Keith,
Take a look at 49CFR173.461 - "Demonstration of Compliance with Tests". One of
the allowed methods to demonstrate compliance is "Calculations or reasoned
evaluation, using reliable and conservative procedures and parameters". I know
this is vague and you'll have to defend your evaluation if necessary but this
option is available. In fact, my former employer (a radiochemical manufacturer)
used to mention this to its university customers to help them decide if they
want to "re-use" its packages for transporting RAM on campus or between
campuses. Typically, the RAM packages come to the HP office where it is opened
and checked for contamination, leakage... After that, the HP office delivers
(or have someone deliver) the packages to the individual labs. To me, it is
easy to defend the practice of using strong tapes to tape the package opening
again and reason that the package should be as good as when it came (my former
employer did have these tested).

In my opinion, if this is a "package" configuration that you'll use often, it
may be worth testing it at least once. If this is a one-time deal, the costs to
have the package tested need to be examined.
In any case, like many previous posters have mentioned, document your test
results or evaluations, whatever they may be. Hope this helps.


Keith Welch wrote:
> 
> 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?     
_____________________________________________________________________ 
Quang Le 
SLAC/OHP 
(650) 926-2610 
<quangle@slac.stanford.edu> 
Note: The above is my own opinion only!  
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