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

Interpretation Response #16-0134

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

Interpretation Response Details

Response Publish Date:

Company Name: Boston University Medical Campus

Individual Name: Mr. Michael P. Walen Jr, MS, CHP

Location State: MA Country: US

View the Interpretation Document

Response text:

March 13, 2017

Mr. Michael P. Whalen Jr, MS, CHP
Radiation Safety Officer & Chief Health Physicist
Boston University Medical Campus
Evans Basement
72 East Concord Street
Boston, MA  02118

Reference No. 16-0134

Dear Mr. Whalen:

This letter is in response to your August 16, 2016, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to transportation of hazardous materials across the Boston University Medical Campus (BUMC).  Specifically, you seek confirmation that a blood irradiator can be shipped without a type B container, provided the transportation is within the contiguous campus and the use of any public roads is restricted. 

In your letter, you note that BUMC is comprised of two entities:  Boston University (BU), a Massachusetts nonprofit educational institution (which includes the medical school), and Boston Medical Center (BMC), a privately owned hospital and teaching affiliate for BU’s medical school.  You further propose a transportation scenario, noting that two public roads will be restricted by the Boston Police during the transportation of the irradiator.  You ask if the shipment in the scenario provided would be excepted from the HMR under § 171.1(d)(4).

The answer is yes.  Section 171.1(d)(4) excepts hazardous material shipments by rail and motor vehicle when the transportation occurs entirely within a facility’s boundary, provided public access is restricted during transportation.  Since your university shares space with the hospital, both are considered part of the BUMC campus.  In addition, if any portion of the hazardous materials movement crosses a public road or track, access to that area must be restricted by signals, lights, gates, or similar controls during that portion of the movement.

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

 

171.1(d)(4)

Regulation Sections

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