Interpretation Response #10-0039R ([Nuclear Diagnostic Products] [Mr. Ken Ali])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Nuclear Diagnostic Products
Individual Name: Mr. Ken Ali
Location State: NJ Country: US
View the Interpretation Document
Response text:
April 30, 2010
Mr. Ken Ali
Radiation Safety Officer
Nuclear Diagnostic Products
101 Roundhill Drive
Rockaway, NJ 07866
Ref. No.: 10-0039R
Dear Mr. Ali:
This responds to your letter concerning whether it is a violation of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) to place the RQ designation on a Dangerous Goods Declaration for "Iodine 131" (131) shipped by aircraft under the HMR.
According to your letter, a small percentage of your company's product is shipped by aircraft via FEDEX. For these shipments, you use a Dangerous Goods Declaration, as packages are classed as Radioactive Yellow II or Radioactive Yellow III. The main radionuclide your company ships is "Iodine 131" in a liquid compound form. When shipping "I-131" in amounts greater than 10 millicuries (0.37GBq), you use the RQ designation on packages and shipping documents in compliance with the definition in §171.8 for hazardous substances listed in §172.101, Appendix A, Table 2. You ask if your understanding is correct that since the amount being shipped is greater than the RQ for "I-131" [0.01 Ci (.00037TBq)] and qualifies as a hazardous substance, the HMR requires that you include the RQ designation on the Declaration of Dangerous Goods document.
Your understanding is correct. Based on the scenario described above, you are shipping a hazardous substance as defined in §171.8 since I-131 is listed in Table 2 to Appendix A in §172.101 and you are shipping in a quantity in one package in excess of the reportable quantity listed in the table. Thus, the letters "RQ" are required to be entered on the shipping paper per §172.203(c)(2) and shown on the package per §172.324(b).
I hope this satisfies your inquiry. If we can be of further assistance, please contact us.
Sincerely,
Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards
172.101
Regulation Sections
| Section | Subject |
|---|---|
| 172.101 | Purpose and use of hazardous materials table |