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Interpretation Response #02-0278 ([Defense Logistics-Agency] [F. Kevin Reilly])

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

Interpretation Response Details

Response Publish Date:

Company Name: Defense Logistics-Agency

Individual Name: F. Kevin Reilly

Location State: VA Country: US

View the Interpretation Document

Response text:

Nov 13, 2002

Mr. F. Kevin Reilly                 Reference. No. 02-0278
Director, Environmental Management
Defense Logistics-Agency
8725 John J. Kingman Road, Suite 3229
Ft. Belvoir, Virginia 22060-6223

Dear Mr. Reilly:

This Is in response to your letter dated October 10, 2002 regarding the shipment of Radioactive material, low specific activity, n.o.s. (UN2912) that is packaged in a non-specification strong tight bulk packaging (i.e., freight container) in accordance with § 173.4127(c)(l) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171 180). Specifically, you ask whether the material may be contained in inner non-bulk packagings.

The answer is yes. Section 173.427(c)(1) authorizes the use of a non-specification strong tight bulk packaging for Radioactive material, low Specific activity, n.o.s. (UN2912).  The fact that the material is further contained in non-bulk packagings is not relevant.

I hope this information is helpful.


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


Regulation Sections

Section Subject
173.427 Transport requirements for low specific activity (LSA) Class 7 (radioactive) material and surface contaminated objects (SCO)