Interpretation Response #16-0133 ([Mr. Mark Hawk])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name:
Individual Name: Mr. Mark Hawk
Location State: TN Country: US
View the Interpretation Document
Response text:
March 15, 2017
Mr. Mark B. Hawk
Hazardous Materials Consultant
49 Palisades Parkway
Oak Ridge, TN 37830
Reference No. 16-0133
Dear Mr. Hawk:
This letter is in response to your August 11, 2016, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the proper shipping name for radioactive materials. You indicate that you are shipping a Type A quantity of non-excepted fissile radioactive material that is not in special form in a Type B(F) packaging. Specifically, you ask whether the proper shipping name is determined by the material being shipped or by the packaging selected to transport the material.
The proper shipping name should be selected based on the package type being transported. The description of contents should reflect the hazard level of the material being transported. Specific to your case, you may prepare the shipment as follows:
1. Transport using a Type B(U)F package: Select the proper shipping name indicating the material is contained in a Type B(U)F package. The content description on a shipping paper should indicate that the Type B(U)F package contains a Type A quantity of fissile material.
2. Transport using a Type AF package: Once you have received a new certificate of compliance stating the Type B(U)F package meets the requirements of a Type AF package, you select the proper shipping name indicating that the material is contained in a Type AF package. Offering for transport under the proper shipping name for a Type AF package requires you to remove all marking, including the nameplate, indicating that the package is a Type B(U)F package and apply all markings, including the nameplate, indicating that the package is a Type AF package.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division