Interpretation Response #19-0127
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: N/A
Individual Name: Dennis Claussen
Location State: WA Country: US
View the Interpretation Document
Response text:
April 29, 2020
Dennis Claussen
Transportation Consultant
723 Hanford Street
Richland, WA 99354
Reference No. 19-0127
Dear Mr. Claussen:
This letter is in response to your November 6, 2019, email and subsequent phone conversation requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to excepted packages of radioactive material. Specifically, you ask whether radioactive material in excepted packages that conform to the requirements of §§ 173.421 and 173.422 must meet the specific requirements of § 173.4a.
The answer is no. The packaging authorization in §§ 173.421 and 173.422 is specific to certain limited quantities of radioactive material and is not related to the excepted quantities exception in § 173.4a. We believe the reference to radioactive materials in excepted packages in § 173.4a(b)(7) is a result of a typographical error in our effort to harmonize the HMR with changes to the international regulations (74 FR 2199; HM-218J). We plan to correct this in a future rulemaking.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division