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Re: Shipping Question
In reply to Steve Frey,
Steve, your point is taken, however, I had hoped that I had implied that
the contents of a "re-used package" would be "secured" safely in a manner
consistent with the way that the original vendors normally convey them
(i.e., using sturdy inner vials, outer containers of plastic or perhaps
lead, dry ice, stability inserts, Styrofoam, popcorn, flo-paks, etc.). My
goal here is not to explore the "Elmo" incompetence factor, but to examine
some reasonable alternatives that would allow licensees to avoid having to
perform the compliance testing (or at least most of it). I'm not talking
about putting a glass vial in an empty box and "cushioning" it with rocks
(worst case scenario)!
I am taking about re-using nearly all of the "packaging" components that
make up a normal "package." If you shipped 1 mCi of P-32 in the exact
configuration that you normally receive it, why can't the evaluation be
made that the package is compliant? Isn't that like comparing oranges with
oranges?
As Bill Lipton pointed out:
". . .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. . ."
When you consider Sec. 173.461 "Demonstration of compliance with tests",
why can't you use number (2)?
(2) "Reference to a previous, satisfactory demonstration of compliance of a
sufficiently similar nature."
The wording does not say that you had to have performed the
demonstration. It just says to make reference to one (the vendor's). We
do that with our moisture/density gauges.
To reiterate, if I use (or re-use) the same packaging components to ship
radioactive materials that a vendor uses to ship thousands of packages, why
is it unreasonable to assume that the package I'm shipping isn't in
compliance? Why can't the re-use of our vendors packaging be considered a
"de-facto" standard of compliance with performance testing? I do agree
that liability would be the most current shipper's, with the caveat that I
believe it would be regardless of who certified the packaging.
I'm not talking about letting Elmo screw things up, or using a package that
got run over by the FedEx truck. . .
Regards,
-Erick Lindstrom
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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