DOT Shipment & Receipt of Radioactive Materials By Mike Zittle Health Physicist for Technician – NRRPT Training UCLA RSD 1/13/2006

Why are You Here? l It’s REQUIRED if you prepare or ship RAM packages! l NRRPT Training

DOT Training Requirements l Subpart H - Training (49 CFR ) l Requirements - 49 CFR (a) 1General Awareness / Familiarization To identify hazardous / radioactive materials –Contact your RSO for more info 2Function - Specific Training Applicable to functions performed –Shipping and Receiving Radioactive Material packages –Site Specific Requirements 3Safety Training – HAZWOPER usually covers this Emergency Response, etc. –Site Specific Requirements Additional DOT Training Requirements MAY apply - Modal Specific

General Awareness / Familiarization 49 CFR (a) l Employee must be able to: –recognize and identify hazardous material and –those materials containing radioactivity that are regulated by DOT as HAZMAT l What is radioactivity and radiation? –Types of radiation? –What are sources of radiation exposure? –Protection from radiation? l What are radiation protection regulations?

Function - Specific Training 49 CFR (a) l Functions include: –Shipping, Carrying, Receiving, and Preparing a package or container l Training is to include: –Shipping Classification, Packaging, Labeling, Marking, Preparation of Shipping Papers –Surveying and Record Keeping –Other information, as necessary

Safety Training 49 CFR (a) l Emergency Response information l Measures to protect the employee l Methods and procedures to prevent accidents l HAZWOPER Training usually satisfies this requirement

Responsibility for Training and Testing - 49 CFR l HAZMAT Employer is responsible for training l HAZMAT Employees MAY NOT perform functions without training l Training may be provided by any source l Employees MUST be tested by appropriate means

DOT Training Requirements l (b) - OSHA or EPA Training –Training to comply with Hazard Communication (HazCom) requirements of 29 CFR or 49 CFR MAY satisfy the requirements of 49 CFR (a)

DOT Training Requirements l (c) - Initial and Recurrent Training –Employee may perform job functions If supervised by a HAZMAT trained employee Training is completed within 90 days l Retraining required every 3 years, for IATA (air shipments), every 2 years l Relevant Training –Previous employer training may satisfy if you have documentation l The HAZMAT Employer is responsible for compliance with DOT regulations

DOT Training Requirements l (d) Recordkeeping –Employer shall keep records of training within the last 3 years –Records for each employee shall be kept until 90 days after separation –Include Employee’s name, training date, training materials (or material location), name and address of trainer, and certification of training

HAZMAT Certification l Since it is the responsibility of the employer to assure that their employees have been trained and tested, only the employer may certify that the employee has been appropriately trained and tested

The Goal of this Training Class

What is the Goal of This Class? l General Awareness / Familiarization –BROAD overview of DOT regulations for transporting hazardous materials Specifically Radioactive Materials l Function - Specific Training –Shipping and Receiving packages containing RAM l Limited Emergency Response Training

Outline l Applicability l NRC Regulations l DOT Regulations l Training Regulations l Package Receiving / Inspection l Safety Training / Emergency Response

Applicability of DOT HazMat Regulations

Applicability of Hazardous Materials (HazMat) Regulations l 49 CFR applies to transportation in commerce –by Rail, Aircraft, Vessel, or Highway –Interstate Carriers –Intrastate Carriers l 49 CFR also applies to preparation of packages or containers for use in transportation - making and certifying packages

DOT Regulations l Most of the applicable regs are found in 49 CFR –Mainly 171, 172, and 173 l There are other regulations that apply!

NRC Regulations

l Packaging and Transportation of Radioactive Material [10 CFR 71] –Requirements for packaging, preparation, and transportation of licensed material l Packaging and Transportation of Radioactive Material [10 CFR 71.5] –Simply says “Follow DOT Regulations” 49 CFR

DOT Regulations

DOT Regulations 49 CFR l DOT Packaging, Marking, and Labeling l Placarding, Accident Reporting l Shipping Papers, Emergency Information l Training, Shipper / Carrier Registration

DOT Regulations l DO NOT Apply to: –RAM produced, used, transported, or stored within an establishment –RAM in a medical device implanted into a human or animal –RAM that has been injected into, ingested, or placed into and are still in humans or live animals

DOT Regulations l DOT Regs are based on IAEA –protection of the public by good packaging l NRC Regs are based on DOT Regs l Agreement States are based on NRC Regs l Air Transport Regs are based on IATA l IATA Regs are based on ICAO l Bottom line: There are Many Regulations!

Steps to Understanding DOT Regulations l Classification l Packaging l Labeling l Radiation Limits l Marking l Shipping Papers l Placarding l Conveyance

DOT Classification

Classification of RAM - Different Levels of DOT Requirements l Exemptions l Excepted (Limited) Quantities l Special / Normal Form l Type A Quantities l Type B Quantities l LSA, SCO, Empty

DOT Classification l Class 7, Radioactive Materials –Other DOT Classes - 49 CFR –Refer to handout of DOT Classes l Class 7 ALWAYS takes precedence EXCEPT for: –Class 1 (Explosives) –Class 5.2 (Organic Peroxides) –Class 4.1 (Wetted Explosives) –Limited Quantities of RAM

Classification l Until January DOT defined radioactive materials with concentrations greater than 70 Bq/g –(0.002 μCi/g or 2 nCi/g or 4200 dpm/g) l Final Rule introduces many new changes l New nuclide-specific exemption activity concentrations and consignment activities

DOT Exemptions l Specific Wastes - 10 CFR –LSC Media / Cocktail and Animal Tissue containing less than 0.05 μCi/g H-3 or C-14 l Either one of these conditions - EXEMPT from DOT Rules (except for aircraft) –49 CFR (d) l No Longer needed – NEW exempt concentrations are greater than these limits

Exempt Quantities* §49CFR (selected nuclides) IsotopeConcentration (Bq/g) Activity (μCi) C Mo I I H * Both the activity concentration and the total activity in the consignment are less than the values specified in the table in § or values derived according to the instructions in §

Classification as Special Form l 49 CFR and l Single, solid piece or sealed capsule –Can only be opened by destruction l Dimensional requirements l Satisfy test requirements of 49 CFR l ALL Special Form materials are classified as Sealed Sources by the NRC, but l Not all Sealed Sources are Special Form materials

Classification as Normal Form l 49 CFR l Anything which is does not qualify as Special Form l Can be solid, liquid, or gaseous

Classification A 1 /A 2 Quantities l A 1 Quantity - (usually greater than A 2 ) –Maximum activity of Special Form material in a Type A Package l A 2 Quantity –Maximum activity of Normal Form material in a Type A Package l No Nuclides are assigned more than Ci, although some are “unlimited”

Classification - Other Quantities l Type B Quantity –Special Form - Exceeds A 1 Quantity –Normal Form - Exceeds A 2 Quantity l Highway Route Controlled Quantity (HRCQ) –Special Form - Exceeds 3000 A 1 Quantity –Normal Form - Exceeds 3000 A 2 Quantity OR –Exceeds 1000 TBq (27,000 Ci), whichever is least

Special Classifications l Excepted Quantities l Empty l LSA l SCO

Excepted (Limited) Quantities / Empty Packages l Greater than nuclide-specific exemption activity concentrations and consignment specified in 49 CFR but less than Type A quantity l “Excepted” from specification packaging, marking, labeling, shipping paper, and certification requirements if not hazardous waste l This material is NOT EXEMPT from DOT regs

LSA and SCO l LSA - Low Specific Activity –Generally pertains to bulk materials like ores, waste, and activated items l SCO - Surface Contaminated Object –Generally for power plant items –Occasionally found on research instruments

Classification l LSA (49 CFR ) –LSA-I, LSA-II, LSA-III l SCO (49 CFR ) –Object which itself is not radioactive, but has RAM on any of its surfaces –SCO-I - non-fixed and fixed contamination on accessible and inaccessible areas –SCO-II - (MORE) non-fixed and fixed contamination on accessible and inaccessible areas than SCO-I –Averaged over 300 cm 2, or over entire surface if less than 300 cm 2

Review of Classifications l Exempt - not considered radioactive (for DOT purposes) - < nuclide-specific exemption activity concentrations and consignment activities l Excepted / Empty - some rules apply, small amounts of activity – NOW require UN # l Type A - More Activity than Excepted l Type B / HRCQ - More Activity than Type A l LSA / SCO - special rules, special material

Transportation Activity Spectrum

General Requirements for All Types of Radioactive Material Packages

Radiation Level Limitations (49 CFR ) l Generally Dose Rates at package surfaces must not exceed 200 mrem/hr l Transport Index (TI) may not exceed 10 l If these levels are exceeded, package must be shipped “Exclusive Use” l Packages exceeding 200 mrem/hr at surface and TI > 10 may not be shipped by aircraft

Exclusive Use l Also known as “Sole Use” or “Full Load” by a single consignor of a conveyance l Radiation Limits –Surface Levels up to 1 rem/hr –Outer Surface of Vehicle up to 200 mrem/hr –10 mrem/hr at 2 meters from the outer surface of the vehicle –2 mrem/hr in normally occupied spaces i.e. Truck Cab Unless operating under provisions of a Federally or State regulated Radiation Protection Program Unless driver is badged with dosimeter(s)

Contamination Control 49 CFR (a) l Level of non-fixed (removable) surface contamination must be ALARA l May not exceed limits specified in Table 9 l Must wipe at least 300 cm 2 –Use absorbent material –Apply moderate pressure –Measure activity on swipe –Must take swipes in areas most likely to have contamination

NEW Contamination Limits - Table 9 (49 CFR ) Exclusive Use Shipments have many more Contamination Control Requirements

Quality Control Requirements (49 CFR ) l Before shipping Class 7 Radioactive material, the offeror must ensure –Packaging is proper –Packaging is in unimpaired condition –Closure devices are installed, secured and free of defects –Neutron absorbers, if required, are present –Instructions for preparing package have been followed

Quality Control Requirements l The offeror must also ensure –Any closure valves, or other openings are closed and sealed –Packages of liquids for air transport have been tested under appropriate atmospheric conditions –The internal pressure will not exceed design criteria –External radiation and contamination levels are within acceptable limits

Packages

Packages General Design Criteria l 49 CFR l Package can withstand normal transport, acceleration, vibration, and resonance l Package materials and components are physically and chemically compatible l Many more criteria, etc.

Type A Packages l Packaging that, together with its contents, –May be used to ship up to the A 1 Limit if Special Form –May be used to ship up to the A 2 Limit if Normal Form –Table of A 1 and A 2 values (49 CFR ) l Will retain integrity and shielding during normal transportation l Must pass tests specified in § /466

Packaging - Type A Package Tests (49 CFR ) l Water Spray Test equivalent to rainfall of 5 cm/hr l Free Drop Test from various distances based on mass –Corner / Rim Drops l Stacking Test - 24 hour load of 5X the mass or 1.9 lbs./in 2, whichever is greater l Penetration Test using 3.2 cm bar of 6 kg dropped from 1 meter

Packaging a Type A Quantity of Radioactive Material l 49 CFR l May use DOT Specification 7A container –§ –Certification of test results for 7A Packaging must be kept on file for one year after shipment FAA inspector asked for this during surprise audit

Packaging Type B, Fissile Materials l Authorized Type B Packages –49 CFR l Authorized fissile material packages –49 CFR l Usually Not Applicable at Research Facilities, Hospitals, etc.

Labeling

Labeling Surface Radiation Level and Transport Index (TI) l 49 CFR l TI - Maximum dose rate in mrem/hr at 1 meter from package surface rounded to the nearest tenth – recorded as dimensionless l If dose rate is less than 0.05 mrem/hr, TI is defined to be 0 l Cannot be greater than 10 - except for Exclusive Use Shipments

Labeling

Labeling - Information l Contents - list of radionuclides –select authorized symbols - (49 CFR ) –H-3, C-14, I-125, P-32, etc. l Activity - SI Units Required (Bq, MBq, GBq) –Ci units are optional – but IF you use them they must be in parentheses – new rule –1 Ci = 3.7 x Bq or 37 GBq l TI - Yellow II and Yellow III only –49 CFR (g)(3)

Labeling a Type A Shipment l Affix 2 White I, Yellow II or III labels as appropriate - 49 CFR –On opposite sides of the package - not bottom –Near marked proper shipping name l Cargo Aircraft Only - Label –If package is authorized for cargo aircraft only 49 CFR (c)

Marking

Marking a Type A Shipment l Package marked with proper shipping name and identification number 49 CFR (a) –NEW Shipping names in table in 49 CFR i.e. Radioactive Material, Type A Package, 7, UN 2915 l Package marked with weight - if greater than 50 kg (110 lbs.) l International Shipments must bear “USA” marking

Marking a Type A Shipment l Package marked as “Type A” in letters at least 13 mm high l The letters “RQ” for Reportable Quantity must be marked on the package along with the shipping name if: –Quantities of RAM are at or above the limits found in Appendix A are in the package l Name and Address of Consignor (Shipper) or Consignee (Receiver) on the package

New Marking Requirement for a Type A Shipment 49 CFR l International Vehicle Registration Code of the country of origin of the design of the package must be marked on the package –United States – “USA”

Shipping Papers refer to “Candy Striper”

Shipping Papers for a Type A Shipment l Proper shipping name, hazard class, UN number l Name of each radionuclide as listed in 49 CFR –49 CFR (d)(1) and (2) –see 49 CFR (f) for mixtures l Description of physical and chemical form –49 CFR (d)(3)

Shipping Papers for a Type A Shipment l “RQ” must appear also either before of after the basic description, if applicable – RQ, Radioactive Material, Type A Package, 7, UN 2915

NEW Proper Shipping Name, Hazard Class, ID Number: Domestic & International 49 CFR Hazardous Materials Table l Radioactive Material, Type A Package, 7, UN2915 l Radioactive Material, excepted package – Limited Quantity of Material, 7, UN2910 l Radioactive Material, excepted package - instruments or articles, 7, UN2911 l Radioactive Material, excepted packages - articles manufactured from natural or depleted uranium or natural thorium, 7, UN2909 l Etc.

Shipping Papers for a Type A Shipment l Activity in SI units, Bq or GBq l Category of label applied to shipment –i.e. RADIOACTIVE WHITE-I l Transport Index (if applicable) –49 CFR (d)(6) l “Cargo Aircraft Only” on shipping paper, if on package

Shipping Papers for a Type A Shipment l Shipper’s Certification - 49 CFR (a) –“This is to certify that the above-named materials are properly classified, described, packaged, marked and labeled, and are in proper condition for transportation according to the applicable regulations of the Department of Transportation.” l Signature - 49 CFR (d) –must be legibly signed by principle, officer, partner, employee of shipper or his agent –may be legibly signed by mechanical means

Shipping Papers for a Type A Shipment l Different rules apply for fissile materials or Highway Route Controlled Quantities –49 CFR l For passenger aircraft - 49 CFR (c)(4) –Requires printed certification stating that: “This shipment contains radioactive material intended for use in, or incident to, research, or medical diagnosis or treatment.”

Emergency Response Information

Emergency Response Information - 49 CFR l Applies to persons shipping RAM l Applies as long as the RAM is in transit l Information must be available immediately l Emergency Response Information –Information used to mitigate an accident –Description and technical name of RAM –Hazards to health, risk of fire, precautions in event of an accident, methods for handling fires, methods for handling spills, first aid measures –NAERG Pages

l Form of information –Printed in legible English –Available for use away from the RAM package l Information is presented on: –A shipping paper –In another document MSDS, NAERG, etc. Emergency Response Information

l Maintenance of information –Carriers information must be immediately accessible to pilots, drivers, etc. Driver’s (are supposed) to carry shipping papers and emergency response information in the driver’s compartment - NOT IN THE BACK OF THE TRUCK WITH THE PACKAGE –Facility Operators Must be immediately available wherever RAM is received, stored, or handled during transit Emergency Response Information

l Emergency Response Phone Number l Shipper must provide a 24-hour number –For use in event of an emergency –Number must be monitored as long as RAM is in transit –Number is of person with specific knowledge of RAM in shipment or with access to someone with specific knowledge –Number is of the shipper or otherwise responsible –The number goes on the shipping paper Emergency Response Information

Placarding

Placarding 49 CFR l Placards go on vehicles –No activity written on it –No nuclide information on it l Placards are required for –LSA, SCO, Exclusive Use Shipments –Yellow III Shipments, and Exclusive Use –Highway Route Controlled Quantity

Special Classifications

Excepted Activity Limits - Table 4 49 CFR A 1 /A 2 Values are listed in 49 CFR

Requirements for Excepted Package - Limited Quantity l Table 4 - Activity Limits for Limited Quantities, Instruments, and Articles l Activity Limits < Table CFR l Package meets general design requirements - 49 CFR l Surface Radiation Levels < 0.5 mrem/hr l Non-fixed contamination on surface meets limits specified in 49 CFR (a) l Outside of inner packaging or outer packaging says “Radioactive”

l Must follow requirements specified in 49 CFR & l If not a hazardous substance or hazardous waste or reportable quantity, then you do not need to follow shipping paper description for RAM or passenger aircraft certification for research or medical use materials Requirements for Excepted Package - Limited Quantity

NEW Requirements for Excepted Package - Limited Quantity l Notice to include name of consignor or consignee and the statement: “This package conforms to the conditions and limitations specified in 49 CFR for radioactive material, excepted package - limited quantity of material, UN 2910.” l Notice must be in or on package, with packing list, or forwarded with the package l GONE with the new final rule!

NEW Requirements for Excepted Package - Limited Quantity l 49 CFR (a) l UN identification number specified in the Hazardous Materials Table in 49 CFR must be marked on outside of package

Excepted Package - Instrument or Article - 49 CFR l Same requirements as for LQ Materials l Dose rate from unshielded item must be < 10 mrem/hr at 10 cm l If shipped Exclusive Use, does rate from the surface of the package must be < 2 mrem/hr –this eliminates Type A packaging requirements which are required when the surface dose rate exceeds 0.5 mrem/hr.

Excepted Package - Instrument or Article l Do not exceed activity limits per article and total limits per package as specified in Table CFR l UN identification number specified in the Hazardous Materials Table in 49 CFR must be marked on outside of package

Activity limits for Limited Quantity Materials Packages, Other Liquids A 2

Activity limits for Limited Quantity Materials Packages, Solids, Normal Form A 2

Limited Quantity Multiple Hazard Shipments l If L.Q. RAM meets definition of another hazard class –Must be classed for the additional hazard –Packaged in accordance with L.Q. RAM requirements –Do not need to include the required notice or follow other shipping paper requirements if the entry “Limited Quantity of Radioactive Material” appears on the shipping paper with basic description

Empty Class 7 Materials l Excepted from shipping paper, certification, and marking requirements (except for UN ID# - NEW) l When packaging is emptied of contents as much as practicable l Dose rate at package surface <0.5 mrem / hr l Outside surface contamination limits met –49 CFR (a)

Empty Class 7 Materials l Package unimpaired and securely closed l Internal contamination <100 times limits in 49 CFR (a) –22 dpm/cm 2 beta/gamma, low toxicity alpha emitters (660,000 dpm/300 cm 2 ) –2.2 dpm/cm 2 other alpha emitters (66,000 dpm/300 cm 2 ) l Labels removed or defaced and “Empty” label applied l Proper UN ID# marked on package

Requirements for LSA and SCO 49 CFR l Additional requirements for LSA and SCO –External Dose Rate Limitations –Activity Limits –Contamination Limits –Must use Industrial Packaging (IP), etc. –Exclusive Use loading and Transporting Requirements

Conveyance

Passenger Aircraft l Radioactive Material on passenger aircraft must be for research or medical use –49 CFR (f) l Transport index must be <3.0 if passengers are on board l Type B Packages are not allowed on passenger aircraft l Separation Distances apply l Cargo Aircraft have fewer restrictions

Carriage by Public Highway

l Packages labeled White I, Yellow II, or Yellow III cannot be carried in compartments occupied by passengers (except couriers) - 49 CFR (c) l General Information –Carriers are responsible for complying with regs and for training of HAZMAT employees –no unnecessary delays in the movement of hazardous materials –Carrier may not accept forbidden materials

Driver Training 49 CFR l Drivers must be trained –Requirements of 49 CFR –Pre-trip safety inspections –Vehicles controls, equipment –Operation of vehicle –Maneuvering tunnels, bridges, RR crossings –Vehicle routing, attendance, smoking, incident reporting –Loading / unloading of HAZMAT

Shipping Papers 49 CFR l Carrier may not accept HAZMAT without shipping papers (unless excepted) l Must be certified by the shipper l Shipping paper must be readily available –within reach when driving or in door compartment –on seat or in door compartment when not at vehicle controls l It is prudent to hand the shipping papers to the driver separate from the package

Contamination of Vehicles 49 CFR l Vehicles used for exclusive use shipments must be surveyed after use –Interior does rates may not exceed 0.5 mrem/hr –Contamination levels must meet limits in 49 CFR (a) l For vehicles used solely for RAM, vehicles must be stenciled “For Radioactive Materials Use Only” and interior dose rates may not exceed 10 mrem/hr

US Postal Service l No air transportation by US Postal Service l No labeled packages l Limited Quantities / Excepted Articles accepted if –1/10 of DOT Limited Quantities l US Postal Service will RARELY (if ever) be used to transport RAM to and from hospitals and research institutions, etc.

Receiving and Opening Radioactive Material Packages

Receiving Packages l When receiving packages containing materials in excess of Type A Quantity: –make arrangements to receive package when offered for delivery –When notified it’s at the carrier’s terminal –Monitor labeled package for external contamination (except if gas or special form) –Monitor labeled package for external radiation levels - White-I, Yellow-II, Yellow-III

Receiving Packages l When receiving packages containing materials not greater than Type A Quantity: –monitor labeled package for external contamination (except gas or special form) l When receiving damaged packages: –monitor ALL packages for external contamination –monitor ALL packages for external radiation levels l Monitoring must be performed within 3 hours - if received during normal working hours 10 CFR

Receiving Packages l Must notify NRC Operations Center if: –Excess contamination is found - DOT contamination limits 10 CFR 71.87(i) –High radiation levels >200 mrem/hr 10 CFR l Must have written procedure for package opening and assure that it is followed

Safety Training 49 CFR (a) l Emergency Response l Measures to protect the employee l Methods for avoiding accidents

Emergency Response l Notify final carrier and NRC if: –Radiation level greater than 200 mrem/hr on package surface –Contamination - averaged over 300 cm 2 >220 dpm / cm 2 beta/gamma, low toxicity alphas >22 dpm / cm 2 other alphas

Immediate Notification of DOT Required by Carrier 49 CFR and.16 l Persons killed l Injuries requiring hospitalization l Carrier or other property damage >$50,000 l Evacuation of general public > 1 hour l Major transportation artery shutdown for > 1 hour l Flight pattern or routine of aircraft is altered l Fire, breakage, spillage or suspected radioactive contamination involving Class 7 shipment

Immediate Notification of DOT Required by Carrier 49 CFR and.16 l Notice shall be given to DOT l Notice involving aircraft made to FAA l Notice involving etiologic agents made to CDC l Info required using DOT Form F –49 CFR (b)

Immediate Notification of DOT Required by Carrier 49 CFR and.16 l Written follow-up required in 30 days l Does not apply to Limited Quantity shipments unless: –Incident must be reported as required by 49 CFR (a) –Incident involves an aircraft –Materials in Packing Group I –Incident involves Hazardous Waste

Measures to Protect the Employee l Training (understand radiation safety) l Protective Clothing l Survey Meter (available, operational) l Procedures l Contamination Check l ALARA –Time, Distance, Shielding

Methods for Avoiding Accidents l Training l Follow Procedures l Check for Contamination l Ask questions, if unsure l Notify if ANYTHING unusual is noted

Hazardous Materials Security New Regulations l 49 CFR new security training requirements –Security Awareness - OSHA/EPA or other training may satisfy this requirement Security risks of transporting HazMat Methods to enhance transportation security How to recognize and respond to possible security threats –In-depth Security Training Must develop HazMat Security Plan Must train employees by 12/22/2003

HazMat Security Plan New - Subpart I l Required for those offering HazMat for transportation in commerce l Required if transporting –HRCQ of Class 7 RAM –>55 pounds of Class 1.1, 1.2, or 1.3 materials –> 1 Liter of material poisonous by inhalation –>3500 gallons liquid or 468 cu.ft. gas –Select agent or toxin regulated by the CDC –Quantities of HazMat requiring placarding

Components of a HAZMAT Security Plan l Assessment of transportation security risks of HazMat listed in l Personnel Security - background checks, etc. l Unauthorized Access l En Route Security l Plan must be in writing l Copies of plan must be available to employees responsible for implementing it l Plan must be updated and revised as necessary

DOT Inspections & Fines

FAA Surprise Inspection at UCLA l Friday AM - unannounced l Inspector randomly pulled a DG Form (Candystriper) from a Fed-Ex shipment in March 2003 l Inspector asked to see Training Records –Training Materials, Tests, and Employee Certifications l HP also provided labeled notebooks containing Type A Package Certifications, Radioactive Materials Licenses, HazMat Security Plan

DOT Fines l $9,800 - Failure to brace packages; Failure to provide employee training; Inaccurate hazard labels; No shipper’s certification, etc. l $3,975 / $4,990 - Failed to create and retain records of employee training and testing, etc. l $4,710 - Did not use SI Units; Did not list RQ designation; No 24-hour number listed, etc. l $6,160 - Used unauthorized Type A Package l

Summary l Get copies of the current radioactive materials license when shipping to anyone –Required for Domestic Shipments –Recommended for International Shipments l Read the Regulations –Maintain a current set of ALL pertinent regulations l Perform Employee Training l Keep COMPLETE Records l Audit your program

References l 10 CFR 20NRC Radiation Safety Rules l 10 CFR 71NRC Transportation Rules l 49 CFR 107Frequent Violations! l 49 CFR 387Insurance l 49 CFR 171General Shipping l 49 CFR 172Tables & Communications Rules l 49 CFR 173Shipping Requirements

References l 49 CFR 174Rail Shipments l 49 CFR 175Air Shipments –IATA Regs cover Air Shipments l 49 CFR 176Boat Shipments l 49 CFR 177Truck or Car Shipments l 49 CFR 178Container Specifications l 49 CFR 179Tank Car Specifications

Security Awareness l All packages must be kept under lock & key when unattended. l Packages may only be released to a licensed courier.