Interpretation Response #04-0072 ([MHF Logistical Solutions, Inc] [Mr. C.S. Fossee])

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

Interpretation Response Details

Response Publish Date: 07/22/2004

Company Name: MHF Logistical Solutions, Inc

Individual Name: Mr. C.S. Fossee

Location State: PA Country: US

View the Interpretation Document

Response text:

Jul 22, 2004

Mr. C.S. Fossee                 Reference No. 04-0072
MHF Logistical Solutions, Inc.
800 Cranberry woods Drive, Suite 450
Cranberry Township, PA 16066-5218

Dear Mr. Fossee:

This is in response to your March 25, 2004 letter concerning the definition of “exclusive use” as referred in § 173.403 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 17 1-180) Your questions are paraphrased and answered as follows:

Q1:   Section 173.403 requires loading and unloading to be carried out in accordance with the “direction” of the consignor or consignee. Does this direction require direct, physical oversight?

Al:    Section 173.403 does not require the physical oversight of the shipment by the consignor or consignee.

Q2:   Section 173.403 requires personnel at the loading and unloading sites to have radiological training. What level of training is required to achieve this requirement?

A2:   Radiological training should be appropriate for the safe handling of the consignment and therefore included in function specific training required by subpart H of Part 172. Training relating to the requirements of 10 CFR 19.12 and the following topics may be provided to the extent such training addresses functions the employee performs. Radiological training for persons loading and unloading packages of radioactive materials should include discussions of the following topics:

1.         Elementary radiological safety including basic terms, radiation exposure, dose rates and doses, radiation risks and minimization of exposures;

2.         Transportation of radioactive materials including descriptions of packages normally handled and common radioactive packages;

3.         Labels, radiation levels and placards;

4.         Required shipping paper information;

5.         Controlling radiation exposures;

6.         Good practices in handling radioactive material packages.

I hope this satisfies your request.

Sincerely,

John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards

173.403

Regulation Sections