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Interpretation Response #99-0143 ([Chem-Nuclear Systems] [Kevin M. Lee])

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

Interpretation Response Details

Response Publish Date:

Company Name: Chem-Nuclear Systems

Individual Name: Kevin M. Lee

Location State: SC Country: US

View the Interpretation Document

Response text:

November 26, 1999


Kevin M. Lee                        Reference No. 99-0143
Licensing Engineer
Chem-Nuclear Systems
740 Osborn Road
Barnwell, SC 29812

Dear Mr. Lee:

This is in response to your May 26, 1999 letter and June 23, 1999 telephone conversation with Mr. Wendell Carriker and Ms. Eileen Mack of the Office of Hazardous Materials Safety.  You asked whether an orange panel marking must be removed or covered on a bulk DOT 7A-Type A package, with a polyethylene liner, that contains residue of “Radioactive material, LSA, n.o.s., 7, UN2912" or “Radioactive material, n.o.s.,7, UN2982.” You stated the package is empty and transported in accordance with § 173.428 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).

Based on the information you provided, if the package is prepared in accordance with § 173.428 (that is; it meets the packaging, definition, and EMPTY labeling requirements specified in that section), then the orange panel and other markings required by the HMR for this material must be removed or covered during transportation.  Furthermore, under § 173.428, the shipper is excepted from having to provide a shipping paper and shipper’s certification.  For your information, please note that the requirements in § 173.422(b) pertaining to training, incident and decontamination reporting would apply.

I hope this satisfies your request.



Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.428 Empty Class 7 (radioactive) materials packaging