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Interpretation Response #02-0058 ([Troxler Electronic Laboratories, Inc.] [Stephen A. Browne])

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

Interpretation Response Details

Response Publish Date:

Company Name: Troxler Electronic Laboratories, Inc.

Individual Name: Stephen A. Browne

Location State: NC Country: US

View the Interpretation Document

Response text:

March 26, 2002

Mr. Stephen A. Browne                    Reference No. 02-0058
Corporate Radiation Safety Officer
Troxler Electronic Laboratories, Inc.
Box 12057
Research Triangle Park, NC 27709

Dear Mr. Browne:

This is in response to your November 13, 2001 letter concerning radioactive packaging requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  We apologize for the delay in responding to your letter due to mail delivery problems many Federal agencies have been experiencing because of screening and decontamination precautions.

Specifically, you request clarification on whether cracks which penetrate the full depth of the wall (either inner or outer), of a shipping case designed to transport scientific gauges containing special form radioactive material would be in violation of the regulations.  You cite § 173.475(b) which states that packaging required to transport these gauges must be "...in unimpaired physical condition, except for superficial marks." You state that these cracks do not meet the requirements in this section.

Your opinion is correct.  The cracks in the shipping case described in your letter compromise the physical integrity of the packaging, increasing the chance that the packaging could fail during incidents normal to transportation.  Scratches and scuffs are examples of surface marks that would not compromise the physical integrity of the packaging and would be considered "superficial marks."

I hope this satisfies your request.

Sincerely,

Delmer F. Bukkubgs
Chief, Standards Developent
Office of Hazardous Materials Standards

173.475(b)

Regulation Sections

Section Subject
173.475 Quality control requirements prior to each shipment of Class 7 (radioactive) materials