Interpretation Response #26-0056
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Halliburton
Individual Name: Lee Heft
Location State: TX Country: US
View the Interpretation Document
Response text:
September 17, 2026
Lee Heft
Corporate Radiation Safety Officer, HSE
Halliburton
3000 N. Sam Houston Pkwy. E.
Houston, TX 77032
Reference No. 26-0056
Dear Mr. Heft:
This letter is in response to your May 6, 2026 email and subsequent correspondence with a member of my staff requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to Type A package surveying. Specifically, you provide pictures and describe Type A packagings bolted into a transport vehicle and not fully accessible. You ask whether surveying all accessible parts of the packagings and of the vehicle would satisfy the requirements of the HMR, including ensuring that the package does not exceed the radiation limits of 2 mSv/h (200 mrem/h) at any point on the external surface of the package in accordance with § 173.441(a).
Yes. Provided you survey the packagings and truck to the best of your ability and the readings are within the required limits, your described procedure for surveying your two Type A packagings bolted into a transport vehicle would be in compliance with the HMR.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Alexander Wolcott
Acting Chief, Regulatory Review & Reinvention
Standards and Rulemaking Division
173.441(a)
Regulation Sections
| Section | Subject |
|---|---|
| 173.441 | Radiation level limitations and exclusive use provisions |