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Interpretation Response #02-0173 ([BAE Systems] [Michael S.Krupka])

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

Interpretation Response Details

Response Publish Date:

Company Name: BAE Systems

Individual Name: Michael S.Krupka

Location State: NH Country: US

View the Interpretation Document

Response text:

Aug 16, 2002

Mr. Michael S. Krupka                    Reference No. 02-0173
Senior I.H. Specialist
BAE Systems
P.O. Box 0868, M/S MER12-1506
Nashua, NH 03061-0868

Dear Mr. Krupka:

This is in response to your letter dated June 6, 2002 requesting clarification of the requirements in § 173.403, under the Hazardous Materials Regulations (HMR; 49 CFR parts 171-180).  Specifically, you ask whether your devices meet the defining criteria for "Radioactive instruments and articles".

You state that specifically manufactured bolts contain a sealed 4 uCi Am-241 foil source.  Also, you state that the bolts function as static-elimination devices within a Light Detection and Ranging (LIDAR) system or a laser targeting pod used to guide ordinance systems.

Based on the information you provided, it is our opinion that your material would meet the definition of "Radioactive instrument or article" as defined in § 173.403 of the HMR.  Should you have further questions, please contact this office.

I hope this satisfies your request.


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


Regulation Sections

Section Subject
173.403 Definitions