Interpretation Response #03-0071 ([SAIC Health Physicist] [Ms. Linda G. Bray])

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

Interpretation Response Details

Response Publish Date: 04/16/2003

Company Name: SAIC Health Physicist

Individual Name: Ms. Linda G. Bray

Location State: CA Country: US

View the Interpretation Document

Response text:

Apr 16, 2003

Ms. Linda G. Bray                Reference No. 03-0071
SAIC Health Physicist
16701 West Bernardo Drive
San Diego, CA 92127

Dear Ms. Bray:

This responds to your letter requesting clarification of the labeling requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  You ask if the “activity” and “transport index” values, when required on a RADIOACTIVE label, may be expressed as less than (<) the maximum initial starting value.  You state that you wish to use permanent labels on a Type A package installed in a Mobile Vehicle and Cargo Inspection System (Mobile VACIS) and that the “activity” and “transport index” values decrease over a time period of between 8 to 15 years.  You also reference a previous clarification letter regarding the use of a permanent shipping paper that remains with the vehicle for its life time (Reference No. 02-0116, June 4, 2002).

The answer to your question is no.  There are no provisions in the HMR to express the value of the “activity” or the “transport index” of a RADIOACTIVE label in a manner other than the actual value.  Our letter of clarification regarding the permanent shipping paper states that the same shipping paper may remain with the Mobile VACIS for its lifetime provided the content (including quantity) of the Type A package remains the same and the Type A package is not reshipped or transferred to another vehicle.  If the content (including quantity) of the Type A package changes (i.e. decreases over time), a new shipping paper would have to be prepared and new RADIOACTIVE labels reflecting the decreased “activity” and “transport index” affixed to the Type A package.  Since radioactive material decays, we suggest that you may wish to prepare a new shipping paper and affix a new label reflecting the new level of activity periodically.

I hope this satisfies your request.

Sincerely,

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

173.403

Regulation Sections