Keith -
I'd like to reaffirm Quang's position. The USDOT doesn't require submittal of your demonstration of compliance with package test requirements, but as a CYA, you need to have documentation on file that demonstrates compliance, in the (admittedly unlikely) event that the USDOT ever inspected you, or in the more likely (but still not too likely) event that the state/NRC asked you to demonstrate compliance. Demonstrating compliance doesn't necessarily mean testing, but you need to feel confident that your documentation is defensible (and testing is the best way), because states and the NRC are authorized to enforce 49 CFR, and may look at this issue during routine inspections (though the degree of effort exerted to do so varies widely). One thing you can count on, however, is that if you ever have an incident involving a RAM package, the investigators will definitely look into the package compliance issue, so its best to be prepared, while hoping that such an incident never occurs.
- Walter Cofer, Fla. Bureau of Radiation Control
-----Original Message-----
From: Quang Le [SMTP:quangle@SLAC.Stanford.EDU]
Sent: Wednesday, September 01, 1999 10:52 AM
To: Multiple recipients of list
Subject: Re: Shipping Question
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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