Interpretation Response #05-0308 ([Lixi, Inc.] [Mr. Robert Savini])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Lixi, Inc.
Individual Name: Mr. Robert Savini
Location State: IL Country: US
View the Interpretation Document
Response text:
Jan 9, 2006
Mr. Robert Savini Reference No. 05-0308
Radiation Safety Officer
Lixi, Inc.
11980 Oak Creek Parkway
Huntley, IL 60142
Dear Mr. Savini:
This is in response to your November 22, 2005 letter and subsequent telephone conversation with a member of my staff requesting clarification regarding the shipping paper requirements for radioactive materials as specified under the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1-180). In your scenario, you offer for transportation excepted packages for radioactive instruments and articles (UN2911). Your questions are paraphrased and answered below.
Q1. Section 173.424 specifies that excepted packages for radioactive instruments and
articles are not subject to the shipping paper requirements unless the item being shipped is a hazardous substance or hazardous waste. If we offer an excepted package that is a
hazardous substance, may we place a document that complies with the Part 172, Subpart
C shipping paper provisions in a pouch that is attached to the side of the package?
Al. Yes. Section 177.8 17(a) specifies that “a person may not accept a hazardous material for transportation or transport a hazardous material by highway unless that person has received a shipping paper prepared in accordance with part 172 of this subchapter or the material is excepted from shipping paper requirements under this subchapter.” Although the carrier must comply with the shipping paper accessibility requirements in
§ 177.8 17(e), the HMR do not prohibit a shipper from placing the shipping paper in a pouch attached to the outside of the completed package.
Q2. If excepted packages for radioactive instruments and articles (UN2911) are authorized to use the shipping paper exception in § 173.424, is a shipper’s certification still required?
A2. No. The exception from shipping paper requirements includes the shipper’s certification.
I hope this information is helpful.
Sincerely,
Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173.424
Regulation Sections
| Section | Subject |
|---|---|
| 173.424 | Excepted packages for radioactive instruments and articles |