Interpretation Response #05-0310 ([Airgas, Inc] [Mr. Randy Porter])

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

Interpretation Response Details

Response Publish Date: 02/27/2006

Company Name: Airgas, Inc

Individual Name: Mr. Randy Porter

Location State: CA Country: US

View the Interpretation Document

Response text:

Feb 27, 2006

Mr. Randy Porter                  Reference No. 05-0310
7000 East Avenue
Airgas, Inc.
Livermore, CA 94551

Dear Mr. Porter

This is in response to your letter requesting clarification of the packaging and marking requirements for the transportation of radioactive materials under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You indicate that you are shipping a Type A quantity of non-fissile radioactive material in a Type B package.

In order to make the shipment you may:

1. Use a Type B packaging for the transportation of a Type A or A quantity of material ( 173.415(c)). However, you must select a proper shipping name indicating that the material is in a Type B packaging. In addition, you should include the isotope on the shipping paper and an indication that the Type B packaging contains a Type A quantity of material; or
2. Use a Type B packaging as a Type A packaging. This requires you to convert a Type B packaging to a Type A packaging by removing or covering all markings (including the specification plate) used to indicate that it is a Type B packaging and replacing them with the appropriate Type A markings. In addition, the Type A packaging is a new design and must be certified as meeting the Type A requirements.

I hope this information is helpful. Please contact us if you require additional assistance.

Sincerely,

John A Gale
Chief, Standards Development
Office of Hazardous Materials Standards

173.415 (c)

Regulation Sections