Interpretation Response #02-0152 ([American Airlines] [Les Adolph])

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

Interpretation Response Details

Response Publish Date: 10/02/2002

Company Name: American Airlines

Individual Name: Les Adolph

Location State: OK Country: US

View the Interpretation Document

Response text:

Oct 2, 2002

Mr. Les Adolph                 Reference No. 02-0152
American Airlines
3900 North Mango Road
P.O. Box 582809 MD 517
Tulsa, OK 74116

Dear Mr. Adolph:

This is in response to your May 30, 2002 letter inquiring whether you are required to check each UN2910 or UN2911 radioactive material shipment under § 173.424(d) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  You state that the shipments consist of radioactive articles, such as exit signs, fuel flow emitters and smoke detectors and that you have their radioactive readings from the manufacturers.

Section 173.424(d) states, in part, that a radioactive instrument or article and its packaging is excepted from the specification packaging, shipping paper and certification, marking and labeling requirements if:

The radiation level at 10 cm (4 in) from any point on the external surface of any unpackaged instrument or article does not exceed 0.1 mSv/hour (10 mrem./hour).

The HMR specify the radiation level limits that must be achieved but do not state how to ascertain whether the levels are within the acceptable limits.  Therefore, you may use any methods or means you deem appropriate to assure that your UN2910 or UN2911 radioactive material shipments do not exceed the limits specified in § 173.424(d), including the usage of radioactive information received from the articles' manufacturers.  However, caution should be exercised when manufacturer's data is used to assess instruments or articles which are not new due to their potential for damage.

I hope this information is helpful.

Sincerely,

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

173.424(d)

Regulation Sections