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Interpretation Response #07-0129 ([SESI Consulting Engineers] [Mr. John Nederfield])

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

Interpretation Response Details

Response Publish Date:

Company Name: SESI Consulting Engineers

Individual Name: Mr. John Nederfield

Location State: NJ Country: US

View the Interpretation Document

Response text:

Sep 6, 2007

Mr. John Nederfield                                    Reference No. 07-0129

SESI Consulting Engineers

12 Maple Avenue

Building A

Pine Brook, NJ 07058

Dear Mr. Nederfield:

This responds to your June 21, 2007 letter regarding the transportation of a nuclear density gauge. As discussed in your June 20, 2007 telephone conversation with Mr. James Williams of the Office of Hazardous Materials Technology staff, you ask if the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) apply to your scenario described below.

According to your letter, over a period ranging from several days to several months, a gauge user drives the gauge from an NRC-approved location to a temporary jobsite, and then back and forth between his home (or hotel) and that jobsite. You ask if the HMR apply to the transportation of the nuclear density gauge under this scenario.

The HMR apply to the transportation of hazardous materials in commerce, as specified in § 171.1, including storage incidental to movement under § 171.8. Transportation of the nuclear density gauge from an NRC-approved location to a temporary jobsite and back and forth between home or hotel and that jobsite is subject to the HMR. Moreover, the nuclear density gauge is being temporarily stored incidental to movement while in the gauge user's home or hotel room.

In addition, the user is subject to NRC and applicable State requirements when transporting the nuclear density gauge, including storage incidental to movement.

I hope this answers your inquiry.


John A. Gale

Chief, Standards Development

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
171.1 Applicability of Hazardous Materials Regulations (HMR) to persons and functions