Re: Shipping Question

[William V Lipton <liptonw@dteenergy.com>]

I appreciate your excellent response on this.  I was trying to say the same thing,
but you're example is more effective.

If  I were the NRC inspector investigating this incident, I would also want to know
whether Elmo has current hazmat employee training!  (A generic orientation wouldn't
be enough.  If he ships radioactive materials, then this has to be included in his
training.)

The opinions expressed are strictly mine.
It's not about dose, it's about trust.

Bill Lipton
liptonw@dteenergy.com

Steve Frey wrote:

> 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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