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Interpretation Response #11-0038 ([Los Alamos National Laboratory] [Mr. Donald Thorp])

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

Interpretation Response Details

Response Publish Date:

Company Name: Los Alamos National Laboratory

Individual Name: Mr. Donald Thorp

Location State: NM Country: US

View the Interpretation Document

Response text:

April 21, 2011

 

 

 

Mr. Donald Thorp

Engineering Manager

Los Alamos National Laboratory

P.O. Box 1663, MS A194

Los Alamos, New Mexico 87545

Ref. No.: 11-0038

Dear Mr. Thorp:

This responds to your February 15, 2011 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if any of the general packaging requirements in § 173.24 apply to a consignment containing radionuclides in quantities that do not exceed both the activity concentration and the total activity limits specified in the table in § 173.436 or the values derived according to the instruction in § 173.433.

The answer is no. Radioactive Material (see § 173.403) means any material containing radionuclides where both the activity concentration and the total activity in the consignment exceed the values specified in the table in § 173.436 or values derived according to the instructions in § 173.433. Based on the information you provide, the consignment is not regulated as a Class 7 (radioactive) material under the HMR because it does not meet the definition of radioactive material. Therefore, provided the material contained in the consignment does not otherwise meet the definition of a hazardous material in § 171.8, the packaging used for the consignment described in your letter is not subject to the HMR (including § 173.24).

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.

Sincerely,

Ben Supko

Acting Chief, Standards Development Branch

Standards and Rulemaking Division

173.403, 173.433

Regulation Sections

Section Subject
173.403 Definitions
173.433 Requirements for determining basic radionuclide values, and for the listing of radionuclides on shipping papers and labels