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Interpretation Response #17-0131

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

Interpretation Response Details

Response Publish Date: 05-01-2019
Company Name: RSB Logistic    Individual Name: Bruce Natske
Location state: SK    Country: CA

View the Interpretation Document

Response text:

May 1, 2019

Bruce Natske
RSB Logistic
219 Cardinal Crescent
Saskatoon, SK S7L 7K8

Reference No. 17-0131

Dear Mr. Natske:

This letter is in response to your November 28, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the labeling and placarding requirements for radioactive materials. Specifically, you ask whether the transport index (TI) of the flat-rack container in the photograph (considered an overpack for purposes of the HMR) you provided can be measured by taking the sum of the TI of the packages contained therein.

The answer is yes. In accordance with § 172.403(h)(3) and Section 5, Paragraph 524 of the International Atomic Energy Agency (IAEA) Regulations, the measurement of the TI for the flat-rack container may be done by either using the TI sum of each package, or by direct measurement. With regards to the hazard communication requirements, in accordance with § 171.26, a Class 7 (radioactive) material being imported into or exported from the United States or passing through the United States in the course of being shipped between places outside the United States may be offered for transportation or transported in accordance with the IAEA Regulations. Furthermore, Section V, Paragraph 543 of the IAEA Regulations states that, instead of using both labels and placards, it is permitted, as an alternative, to use enlarged labels only, where appropriate, as shown in Figures 2-4, except having the minimum size shown in Figure 6. Therefore, the flat-rack container shown in the photograph provided may display an enlarged "RADIOACTIVE YELLOW-III" label.

I hope this information is helpful. Please contact us if we can be of further assistance.


Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

172.403(h)(3), 171.26

Regulation Sections

Section Subject
§ 171.26 Additional requirements for the use of the IAEA Regulations