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Interpretation Response #20-0031

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: Mark B. Hawk

Location State: TN Country: US

View the Interpretation Document

Response text:

May 19, 2020

Mark B. Hawk
Packaging Management Council Coordinator
8116 Villa Grande Lane
Knoxville, TN  37938

Reference No. 20-0031

Dear Mr. Hawk:

This letter is in response to your April 9, 2020, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to Class 7 (radioactive) materials not listed in the §§ 173.435 or 173.436 tables.

We have paraphrased and answered your questions as follows:

Q1. You ask whether the name of each radionuclide needs to be listed on the shipping paper when none of the radionuclides are found on the §§ 173.435 or 173.436 tables.

A1. The answer is no, unless the Class 7 (radioactive) material is a mixture. In accordance with § 172.203(d)(1), the name of each radionuclide listed in the § 173.435 table must be displayed on the shipping paper. Furthermore, § 172.203(d)(1) requires that if the Class 7 (radioactive) material is a mixture of radionuclides, the names of the radionuclides that need to be displayed on the shipping paper are to be determined in accordance with § 173.433(g). Therefore, if the shipment is not a mixture of radionuclides, and the radionuclide is not found on the § 173.435 table, the name of the radionuclide is not required to be on the shipping paper. However, it is permissible to list the radionuclide on the shipping paper even if it is not listed on the § 173.435 table.

Q2. You ask whether the name of each radionuclide needs to be listed on the label when none of the radionuclides are found on the §§ 173.435 or 173.436 tables.

A2. The answer is no, unless the Class 7 (radioactive) material is a mixture. In accordance with § 172.403(g)(1), except for LSA-1 material, the name of each radionuclide listed in the § 173.435 table must be displayed on the label. Furthermore, § 172.403(g)(1) requires that if the Class 7 (radioactive) material is a mixture of radionuclides, with consideration of space available on the label, the radionuclides that must be shown must be determined in accordance with §173.433(g). Therefore, if the shipment is not a mixture of radionuclides, and the radionuclide is not found on the § 173.435 table, the name of the radionuclide is not required to be on the label. However, it is permissible to list the radionuclide on the label even if it is not listed on the § 173.435 table.

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

173.435, 173.436, 172.203(d)(1), 173.433(g), 172.403(g)(1),

Regulation Sections

Section Subject
172.203 Additional description requirements
172.403 Class 7 (radioactive) material
173.433 Requirements for determining basic radionuclide values, and for the listing of radionuclides on shipping papers and labels
173.435 Table of A1 and A2 values for radionuclides
173.436 Exempt material activity concentrations and exempt consignment activity limits for radionuclides