Interpretation Response #11-0302
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
April 2, 2012
Mr. David Wilson
Packaging and Transportation Project Manager
Navarro Research and Engineering, Inc.
669 Emory Valley Road
Oak Ridge, TN 37830
Reference No.: 11-0302
Dear Mr. Wilson:
This is in response to your November 17, 2011 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) as they pertain to the reuse and reconditioning provisions of § 173.28. Specifically you ask if the reuse and reconditioning provisions of § 173.28 are applicable to Type B(U), Type B(M), and fissile material packagings.
The answer to your question is yes. Subpart I of part 173 describes the shippers general requirements for Class 7 (radioactive) materials. General design requirements are discussed in § 173.410. The introductory text to § 173.410 states that each package used for the shipment of Class 7 materials must be designed to the requirements of this section, as well as meet the requirements of subparts A and B of this part. The section you reference, § 173.28 is found in subpart B of part 173, and thus the reuse and reconditioning provisions found in § 173.28 apply to shipments of Type B(U), Type B(M), or fissile packagings.
I hope this satisfies your inquiry. Please contact us if we can be of further assistance.
Senior Regulatory Advisor
Standards and Rulemaking Division
|§ 173.410||General design requirements|