Interpretation Response #01-0241 ([Westinghouse] [Mr. Christian W. Solum])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Westinghouse
Individual Name: Mr. Christian W. Solum
Location State: SC Country: US
View the Interpretation Document
Response text:
October 19, 2001
Mr. Christian W. Solum Reference No. 01-0241
Principal Hazardous Materials Specialist
Westinghouse
Savannah River Company
Aiken, SC 29808
Dear Mr. Solum:
This is in response to your September 14, 2001 letter concerning shipping paper and marking requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
You have a hazardous material described as “Radioactive material n.o.s., 7, UN 2982.” This material does not meet or exceed the reportable quantity (RQ) for any radionuclide, however, it does exceed the RQ for mercury. You ask if the HMR allows an offeror of a Class 7 material that meets or exceeds the RQ for a hazardous substance other than a radionuclide to identify the chemical hazardous substance by name and enter the hazardous substance in parentheses on a shipping paper entry or as a package marking. You state that Class 7 materials are excepted from these requirements by §§ 172.203(c) and 172.324(a).
Your understanding is incorrect that §§ 172.203(c) and 172.324(a) except all Class 7 materials from the shipping paper and package marking requirements for hazardous substances other than radionuclides. Section 172.203(c) excepts Class 7 materials that are described in accordance with § 172.203(d) from the additional shipping paper description for hazardous substances. Section 172.203(d)(2) requires the name of each radionuclide to be shown on the shipping papers. Only if your material is described in accordance with § 172.203(d) is it excepted from § 172.203(c). The same holds true for § 172.324; you are only excepted from the package marking requirements for hazardous substances if your radioactive material is labeled in accordance with § 172.403. Section 172.403(g) requires that the name of the radionuclides is identified on the label. Only if your material is labeled in accordance with § 172.403 is it excepted from the package marking requirements of § 172.324. If your material is not described in accordance with § 172.203(d) and your package is not labeled in accordance with § 172.403, you must identify mercury as a hazardous substance on your shipping papers and also in your package markings.
I hope this satisfies your request.
Sincerely,
Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards
172.203
Regulation Sections
| Section | Subject |
|---|---|
| 172.203 | Additional description requirements |