Interpretation Response #11-0216 ([Mirion Technologies] [Mr. James E. Lynch])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 11/08/2011

Company Name: Mirion Technologies

Individual Name: Mr. James E. Lynch

Location State: NY Country: US

View the Interpretation Document

Response text:

November 8, 2011

Mr. James E. Lynch

Mirion Technologies

315 Daniel Zenker Dr.

Building 300 iST Center

Horseheads, NY 14845

Ref. No. 11-0216

Dear Mr. Lynch:

This responds to your September 6, 2011 request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to radiation detectors. In your letter, you describe your company"s radiation detector as a non-refillable and hermetically sealed welded metallic cylinder with up to three brazed ceramic-to-metal seals (small electrical penetrations) that contains a Division 2.2 (Non-flammable compressed gas) material. Your questions are summarized and answered as follows:

Q1) Section § 173.310 contains regulations applicable to radiation detectors. Does the radiation detector described in your letter meet the definition of "single-trip" and "welded metal inside container" as required by § 173.310(a).

A1) Yes. Section 173.310(a) requires a radiation detector to be single-trip, hermetically sealed, welded metal inside container that will not fragment upon impact. The radiation detector described in your letter is a "welded metal inside container." The term "single-trip" means that the inner packaging is not intended to be refilled and reshipped after having been previously emptied.

Q2) You plan to include a vendor certification letter that the product and its packaging conforms to § 173.310. Will customers be able to use the letter/certification to return the product to your company if the customers use your packaging materials and procedure?

A2) Yes. However, in accordance with § 173.22 it is the shipper"s responsibility to comply with aspects of the HMR applicable to offering a hazardous material for transportation. The

letter/certification that you plan to provide your customers will provide valuable information to assist them in satisfying the compliance responsibilities specified in § 173.22.

I hope this answers your inquiry. If you need additional assistance, please contact this office at (202) 366-8553.

Sincerely,

Ben Supko

Acting Chief, Standards Development

Standards and Rulemaking Division

173.310, 173.22

Regulation Sections