Re: Shipping Question

[Steve Frey <sfreyohp@SLAC.Stanford.EDU>]

A fellow Radsafer asked:

>
> Regarding the "re-use" of packing received by commercial vendors, ...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? 


You cannot, at least as a default in every case. The reason is that the
shipping regulation performance test requirements speak specifically to
'package', not 'packaging'. The distinction is important. Packaging is the
collective assemblage of logistical materials for purposes of transporting
'contents' . 'Contents' are in this realm are otherwise uncontained items or
materials. 'Package' is 'packaging plus contents'. The regulatory reference to
'package' restricts the Type A certification to only that exact packaging with
only those exact contents in the exact configuration with which the package was
analyzed/tested to ensure regulatorily-adequate shipping performance.

Simply switching tape to resecure a Type A fiberboard box to send a
freshly-received radiotracer from a campus shipping & receiving (S&R)
department onward to its user in another building affiliated with the campus
would seem to be a trivial departure from the original state of the 'package',
even if weaker tape is used (note: never use masking tape! It tends to fail by
simply looking at it). 
 
However, if some leftover packaging items from a Type A shipment of radioactive
material are reused in a different configuration or with different contents,
the prospect of package failure becomes more risky.

Suppose you are a campus RSO. Your duties call you away from the site on the
day that an urgent need for a transfer of RAM on campus arises. Elmo the
Expediter, who knows 'how to get things done fast', arrives on the scene in the
S&R department. He takes an emptied, leftover box that was used originally to
ship two millicuries of P-32 ATP gamma from "SuperDuper Radiochemicals
Corporation" to the university (a Type A shipment). Elmo puts a "safely
smaller", one-millicurie quantity of the same type and form of RAM, given to
him in an ordinary glass vial, into the empty box. He then shuts the box, tapes
it closed with more layers of tape than the original had, and sends it on its
way, thinking that the box will maintain the integrity of the glass vial if it
should fall up to at least 30 feet, because that's one of the shipping
performance criteria he's heard about which the "Type A Package" printed-label
on the box certifies for liquid RAM. Along the way, the deliveryperson trips
and drops the package. It falls the short distance from his/her hands to the
floor. The glass vial inside breaks, the contents leak, and a radiological
incident occurs. Elmo yells that SuperDuper should be sued, because its box
failed to prevent leakage of contents in a fall of a far smaller distance the
regulatory design criteria for shipping Type A quantities of liquid RAM.

Elmo's position would be without regulatory merit. His mistake would be in his
assumption that the outermost shipping box alone was a Type A package. The
outermost shipping box merely is one of the components making up the package's
packaging. When packaging is used in a manner different than that for which it
was Type A-certified as part of an overall package, all bets are off,
regulatorily and performance-wise. His later discovery that the box was Type
A-certified using shock-resistant vials cushioned by fiberboard or styrofoam
spacers or inner containers, not simply an empty outer package inside of which
his glass vial could be flung around, jarred, jostled, and thereby weakened,
might help him in future situations. But it won't help him or you  with this
postulated incident.

So, simply acquiring a product vendor's Type A shipping performance test
results or certification to use as your own is false security. The tests,
certification, and liability are not transferable. Responsibility for Type A
shipping performance assurance lies strictly with the current shipper.

After you, as the RSO, cope with the disruption to your busy schedule to
conduct the investigation of the above incident, you might be tempted to
require that Elmo get a tattoo that reads "When in doubt, ask the RSO first!".

Steve

******************************************************
Steve Frey, Head
Operational Health Physics (OHP) Department
Stanford Linear Accelerator Center (SLAC)
Phone:(650) 926-3839 (office),
      (650) 926-3030 (fax),
E-mail address: sfreyohp@SLAC.Stanford.EDU
Any thoughts expressed here are not meant 
to speak for SLAC or any other party in any 
capacity unless so stated.
*******************************************************
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