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Interpretation Response #01-0107 ([Radian International] [Mr. Andrew Romach])

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

Interpretation Response Details

Response Publish Date:

Company Name: Radian International

Individual Name: Mr. Andrew Romach

Location State: NC Country: US

View the Interpretation Document

Response text:

JUL 31, 2001


Mr. Andrew Romach                      Reference No.: 01-0107
Regulatory Manager
Radian International
P.O. Box 13000
Research Triangle Park, NC 27709

Dear Mr. Romach:

This is in response to your April 30, 2001 letter inquiring whether your light bulb meets the definition of a Class 7 (radioactive) material under 49 CFR 173.403. The light bulb contains a glass "starter bottle." The bottle's interior surface is coated with a solution containing a radionuclide. Specifically, you ask whether the specific activity is calculated by using the entire weight of the coated starter bottle or by using the actual weight of the coating.

The specific activity is calculated by using the actual weight of the coating on the starter bottle. If the specific activity is 70 Bq per gram or lower, the light bulb does not meet the definition of Class 7 (radioactive) materials and is not subject to the Hazardous Materials Regulations. If the specific activity is greater than 70 Bq per gram, you may be able to offer the light bulb for transportation as a limited quantity material or surface contaminated object in an excepted package.

This information addresses only the transportation of the light bulbs in question. We suggest that you review the U.S. Nuclear Regulatory Commission regulations in Title 10 of the Code of Federal Regulations regarding the use, possession and disposal of these light bulbs.

I trust you find this information helpful.



Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.403 Definitions