Interpretation Response #06-0211 ([URS Corporation] [Mr. Andrew N. Romach])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: URS Corporation
Individual Name: Mr. Andrew N. Romach
Location State: NC Country: US
View the Interpretation Document
Response text:
Mar 26, 2007
Mr. Andrew N. Romach Reference No. 06-0211
URS Corporation
1600 Perimeter Park Drive
Morrisville, NC 27560
Dear Mr. Romach:
This is in response to your September 15, 2006 letter regarding the transport of limited quantity radioactive materials as specified under the Hazardous Materials Regulations HMR; 49 CFR Parts 171-180). Specifically, you ask if a packaged material that meets the criteria of an excepted package of radioactive material when shipped as part of a consignment hut no longer meets the criteria of a radioactive material when the consignment is broken apart and shipped separately is allowed to retain the “UN2911” marking under the HMR and be shipped as unregulated material?
The answer is no. An excepted package of radioactive material with identification markings that meets no other hazard class nor the definition of a Class 7 (radioactive) material as a result of falling below the exempt consignment activity limits is considered residue and may only be transported as unregulated material by removing, obliterating, or securely covering the identification markings on the outside of the package. Therefore, if the markings remain visible, the packaging must continue to comply with the excepted package containing radioactive material provisions in § 173.422. Generally, the provisions in § 173.422 require t packagings to be prepared in accordance with the applicable packaging section, marked with the appropriate identification number, and comply with the incident reporting provisions in § 171.15 and 171.16.
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Edward T. Mazzullo
Director, Office of Hazardous
Materials Standards
173.422