USA Banner

Official US Government Icon

Official websites use .gov
A .gov website belongs to an official government organization in the United States.

Secure Site Icon

Secure .gov websites use HTTPS
A lock ( ) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites.

U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #11-0216 ([Mirion Technologies] [Mr. James E. Lynch])

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

Interpretation Response Details

Response Publish Date:

Company Name: Mirion Technologies

Individual Name: Mr. James E. Lynch

Location State: NY Country: US

View the Interpretation Document

Response text:

November 8, 2011

 

 

Mr. James E. Lynch

Mirion Technologies

315 Daniel Zenker Dr.

Building 300 iST Center

Horseheads, NY 14845

Ref. No. 11-0216

Dear Mr. Lynch:

This responds to your September 6, 2011 request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to radiation detectors. In your letter, you describe your company"s radiation detector as a non-refillable and hermetically sealed welded metallic cylinder with up to three brazed ceramic-to-metal seals (small electrical penetrations) that contains a Division 2.2 (Non-flammable compressed gas) material. Your questions are summarized and answered as follows:

Q1) Section § 173.310 contains regulations applicable to radiation detectors. Does the radiation detector described in your letter meet the definition of "single-trip" and "welded metal inside container" as required by § 173.310(a).

A1) Yes. Section 173.310(a) requires a radiation detector to be single-trip, hermetically sealed, welded metal inside container that will not fragment upon impact. The radiation detector described in your letter is a "welded metal inside container." The term "single-trip" means that the inner packaging is not intended to be refilled and reshipped after having been previously emptied.

Q2) You plan to include a vendor certification letter that the product and its packaging conforms to § 173.310. Will customers be able to use the letter/certification to return the product to your company if the customers use your packaging materials and procedure?

A2) Yes. However, in accordance with § 173.22 it is the shipper"s responsibility to comply with aspects of the HMR applicable to offering a hazardous material for transportation. The

letter/certification that you plan to provide your customers will provide valuable information to assist them in satisfying the compliance responsibilities specified in § 173.22.

I hope this answers your inquiry. If you need additional assistance, please contact this office at (202) 366-8553.

Sincerely,

Ben Supko

Acting Chief, Standards Development

Standards and Rulemaking Division

173.310, 173.22

Regulation Sections

Section Subject
173.22 Shipper's responsibility
173.310 Exceptions for radiation detectors