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Interpretation Response #02-0296

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

Interpretation Response Details

Response Publish Date: 01-28-2003
Company Name: Cameco Corporation    Individual Name: Bill Ledsham
Country: CA

View the Interpretation Document

Response text:

Jan 28, 2003

Mr. Bill Ledsham                 Reference No. 02-0296
Cameco Corporation
2121 11th Street West
Saskatoon, Saskatchewan S7M 1J3

Dear Mr. Ledsham:

This is in response to your November 4, 2002 letter requesting a clarification of the marking and labeling requirements for low specific activity (LSA) material shipped as exclusive use under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask whether the Canadian exclusive use labeling exemption of Section 16(5)(c) of The Canadian Nuclear Safety Commission Packaging and Transport of Nuclear Substances Regulations, which closely mirrors that of 49 CFR 173.427(a)(6)(vi), is accepted in the United States or must each package in the shipment be labeled with appropriate category labels in accordance with the International Atomic Energy Agency (IAEA) Safety Series 6 paragraphs 440 - 442, or IAEA TS-R-1 paragraphs 541-545.

As you correctly stated in your letter, § 171.12a(a) and (b) provides for hazardous material shipments originating in Canada, packaged and labeled in accordance with Canadian Transport Dangerous Goods (TDG) Regulations, to be offered for transport into the United States, if the relevant conditions and limitations from § 171.12a(b)(1) through (b)(18) are met.  The condition prescribed in § 171.12a(b)(8) states that a Class 7 (Radioactive) material must conform to the provisions of § 171.12(d), which require conformance with the IAEA Safety Series 6 or TS-R-1.

TS-R-1, in paragraph 540, authorizes the packages to be marked "RADIOACTIVE LSA-I" or "RADIOACTIVE SCO-I," as appropriate.  Therefore, in your scenario, your packages marked "RADIOACTIVE-LSA-I: EXCLUSIVE USE" are acceptable.  Your wording "EXCLUSIVE USE" is considered to be additional information.

I hope this information is helpful.


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


Regulation Sections

Section Subject
§ 173.247 Bulk packaging for certain elevated temperature materials