Re: Shipping Question

[Erick Lindstrom <avrel@gemini.oscs.montana.edu>]

Radsafers

Regarding the "re-use" of packing received by commercial
vendors, has anyone requested the documentation that those vendors have
on file (e.g., has anyone asked ICN, Amersham, NEN, etc., for their
documentation demonstrating compliance with tests)?  Though I
personally have not, I have in the past "re-used" containers
from those vendors for domestic transfers.  I will admit that I go
overboard when I tape/seal the packages up, but when they are shipped I
am more than confident that they exceed the relevant testing
standards (be they the impact, submerge, temperature, percussion, or the
punt, pass and kick competition).  Most of the time we receive brand
new pristine packaging.  If I inspect the packaging to be
"re-used" for defects and find none (yes, a matter of
judgement), then seal the package to the nth degree,  why should I
not assume that the package is compliant?  

Why can't it be construed that you are COMPLIANT by your
"association" with the COMPLIANT vendor that transferred the
packaging to you in the first place?  Somebody will probably point
out one flaw in that logic is that if you don't have the compliance
testing documentation, then you are not compliant.  Therefore, I
suppose the question is, if you have the documentation that the vendor
uses (and perhaps that documentation comes from the packaging
manufacturer) are you then compliant?

We use vendor documentation regarding compliance testing for the
containers that our moisture/density gauges are transported in, and the
NRC Inspection Branch has never had a problem with that.

Regards,

-Erick




At 09:52 AM 9/1/1999 -0500, you wrote:
> 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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Erick Lindstrom
Radiation Safety Officer
Montana State University
1160 Research Drive
Bozeman,  MT  59718-6856
Voice: (406) 582-5477, 5479, 5485
Fax:    (406) 586-2478 - if number not working use
582-5700
e-mail: avrel@montana.edu

On-Campus
Communications:

P.O. Box 170510
Bozeman, MT  59715-0510

Voice: Ext. 2108

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