1. DOT Shipment & Receipt of Radioactive Materials
1/13/2006
DOT Shipment & Receipt of Radioactive Materials

2. Why are You Here? It’s REQUIRED if you prepare or ship RAM packages!
DOT requires training every three years
IATA requires training every two years
Applicable when shipping via domestic air
Applicable when shipping international
FedEx has their own rules, based on IATA rules

3. DOT Training Requirements
Subpart H - Training (49 CFR )
Requirements - 49 CFR (a)
General Awareness / Familiarization
To identify hazardous / radioactive materials
Contact your RSO for more info
Function - Specific Training
Applicable to functions performed
Shipping and Receiving Radioactive Material packages
Site Specific Requirements
Safety Training – Annual refresher covers this
Emergency Response, etc.
4 Security Awareness Training

4. General Awareness / Familiarization 49 CFR 172.704(a)
Employee must be able to:
recognize and identify hazardous material and
those materials containing radioactivity that are regulated by DOT as HAZMAT
What is radioactivity and radiation?
Types of radiation?
What are sources of radiation exposure?
Protection from radiation?
What are radiation protection regulations?

5. Function - Specific Training 49 CFR 172.704(a)
Functions include:
Shipping, Carrying, Receiving, and Preparing a package or container
Training is to include:
Shipping Classification, Packaging, Labeling, Marking, Preparation of Shipping Papers
Surveying and Record Keeping
Other information, as necessary

6. Safety Training 49 CFR 172.704(a)
Emergency Response information
Measures to protect the employee
Methods and procedures to prevent accidents
HAZWOPER Training usually satisfies this requirement

7. Security Awareness
Awareness of security risks associated with transportation & methods to enhance security.
& Security of stored material & control of material not in storage.
How to recognize & respond to possible threats.
Emergency procedures and 24-hour telephone numbers.

8. Responsibility for Training and Testing - 49 CFR 172.702
HAZMAT Employer is responsible for training
HAZMAT Employees MAY NOT perform functions without training
Training may be provided by any source
Employees MUST be tested by appropriate means

9. DOT Training Requirements
(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)

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

11. DOT Training Requirements
(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

12. HAZMAT Certification
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

13. The Goal of this Training Class

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

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

16. Applicability of DOT HazMat Regulations

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

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

19. NRC Regulations

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

21. DOT Regulations

22. DOT Regulations 49 CFR 170-189 DOT Packaging, Marking, and Labeling
Placarding, Accident Reporting
Shipping Papers, Emergency Information
Training, Shipper / Carrier Registration

23. DOT Regulations 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

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

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

26. DOT Classification

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

28. DOT Classification Class 7, Radioactive Materials
Other DOT Classes - 49 CFR 173.2
Refer to handout of DOT Classes
Class 7 ALWAYS takes precedence EXCEPT for:
Class 1 (Explosives)
Class 5.2 (Organic Peroxides)
Class 4.1 (Wetted Explosives)
Limited Quantities of RAM

29. Classification
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)
Final Rule introduces many new changes
New nuclide-specific exemption activity concentrations and consignment activities

30. DOT Exemptions Specific Wastes - 10 CFR 20.2005
LSC Media / Cocktail and Animal Tissue
containing less than 0.05 μCi/g H-3 or C-14
Either one of these conditions - EXEMPT from DOT Rules (except for aircraft)
49 CFR (d)
No Longer needed – NEW exempt concentrations are greater than these limits

31. Exempt Quantities* §49CFR173.436 (selected nuclides)
Isotope
Concentration (Bq/g)
Activity (μCi)
C-14
104
270
Mo-99
102 27
I-123
I-131
H-3
106
27000
* 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 §

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

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

34. Classification A1/A2 Quantities
A1 Quantity - (usually greater than A2)
Maximum activity of Special Form material in a Type A Package
A2 Quantity
Maximum activity of Normal Form material in a Type A Package
No Nuclides are assigned more than Ci, although some are “unlimited”

35. Classification - Other Quantities
Type B Quantity
Special Form - Exceeds A1 Quantity
Normal Form - Exceeds A2 Quantity
Highway Route Controlled Quantity (HRCQ)
Special Form - Exceeds 3000 A1 Quantity
Normal Form - Exceeds 3000 A2 Quantity OR
Exceeds 1000 TBq (27,000 Ci), whichever is least

36. Special Classifications
Excepted Quantities
Empty
LSA
SCO

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

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

39. Classification LSA (49 CFR 173.403) SCO (49 CFR 173.403)
LSA-I, LSA-II, LSA-III
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 cm2, or over entire surface if less than 300 cm2

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

41. Transportation Activity Spectrum

42. General Requirements for All Types of Radioactive Material Packages

43. Radiation Level Limitations (49 CFR 173.441)
Generally Dose Rates at package surfaces must not exceed 200 mrem/hr
Transport Index (TI) may not exceed 10
If these levels are exceeded, package must be shipped “Exclusive Use”
Packages exceeding 200 mrem/hr at surface and TI > 10 may not be shipped by aircraft

44. Exclusive Use
Also known as “Sole Use” or “Full Load” by a single consignor of a conveyance
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)

45. Contamination Control 49 CFR 173.443(a)
Level of non-fixed (removable) surface contamination must be ALARA
May not exceed limits specified in Table 9
Must wipe at least 300 cm2
Use absorbent material
Apply moderate pressure
Measure activity on swipe
Must take swipes in areas most likely to have contamination

46. NEW Contamination Limits - Table 9 (49 CFR 173.443)
Exclusive Use Shipments have many more Contamination Control Requirements

47. Quality Control Requirements (49 CFR 173.475)
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

48. Quality Control Requirements
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

49. Packages

50. Packages General Design Criteria
1/13/2006
Packages General Design Criteria
49 CFR
Package can withstand normal transport, acceleration, vibration, and resonance
Package materials and components are physically and chemically compatible
Many more criteria, etc.

51. Type A Packages Packaging that, together with its contents,
May be used to ship up to the A1 Limit if Special Form
May be used to ship up to the A2 Limit if Normal Form
Table of A1 and A2 values (49 CFR )
Will retain integrity and shielding during normal transportation
Must pass tests specified in § /466

52. Packaging - Type A Package Tests (49 CFR 173.465)
Water Spray Test equivalent to rainfall of 5 cm/hr
Free Drop Test from various distances based on mass
Corner / Rim Drops
Stacking Test - 24 hour load of 5X the mass or 1.9 lbs./in2, whichever is greater
Penetration Test using 3.2 cm bar of 6 kg dropped from 1 meter

53. Packaging a Type A Quantity of Radioactive Material
49 CFR
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

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

55. Labeling

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

57. Labeling

58. Labeling - Information
Contents - list of radionuclides
select authorized symbols - (49 CFR )
H-3, C-14, I-125, P-32, etc.
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 1010 Bq or 37 GBq
TI - Yellow II and Yellow III only
49 CFR (g)(3)

59. Labeling a Type A Shipment
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
Cargo Aircraft Only - Label
If package is authorized for cargo aircraft only
49 CFR (c)

60. Marking

61. Marking a Type A Shipment
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
Package marked with weight - if greater than 50 kg (110 lbs.)
International Shipments must bear “USA” marking

62. Marking a Type A Shipment
Package marked as “Type A” in letters at least 13 mm high
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
Name and Address of Consignor (Shipper) or Consignee (Receiver) on the package

63. New Marking Requirement for a Type A Shipment 49 CFR 172.310
International Vehicle Registration Code of the country of origin of the design of the package must be marked on the package
United States – “USA”

64. Shipping Papers refer to “Candy Striper”

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

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

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

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

69. Shipping Papers for a Type A Shipment
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.”
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

70. Shipping Papers for a Type A Shipment
Different rules apply for fissile materials or Highway Route Controlled Quantities
49 CFR
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.”

71. Emergency Response Information

72. Emergency Response Information - 49 CFR 172.600
Applies to persons shipping RAM
Applies as long as the RAM is in transit
Information must be available immediately
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

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

74. Emergency Response Information
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

75. Emergency Response Information
Emergency Response Phone Number
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

76. Placarding

77. Placarding 49 CFR 172.500 Placards go on vehicles
No activity written on it
No nuclide information on it
Placards are required for
LSA, SCO, Exclusive Use Shipments
Yellow III Shipments, and Exclusive Use
Highway Route Controlled Quantity

78. Special Classifications

79. Excepted Activity Limits - Table 4 49 CFR 173.425
A1/A2 Values are listed in 49 CFR

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

81. Requirements for Excepted Package - Limited Quantity
Must follow requirements specified in 49 CFR &
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

82. NEW Requirements for Excepted Package - Limited Quantity
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.”
Notice must be in or on package, with packing list, or forwarded with the package
GONE with the new final rule!

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

84. Excepted Package - Instrument or Article - 49 CFR 173.424
Same requirements as for LQ Materials
Dose rate from unshielded item must be < 10 mrem/hr at 10 cm
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.

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

86. Activity limits for Limited Quantity Materials Packages, Other Liquids - 10-4 A2

87. Activity limits for Limited Quantity Materials Packages, Solids, Normal Form - 10-3 A2

88. Limited Quantity Multiple Hazard Shipments
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

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

90. Empty Class 7 Materials Package unimpaired and securely closed
Internal contamination <100 times limits in 49 CFR (a)
22 dpm/cm2 beta/gamma, low toxicity alpha emitters (660,000 dpm/300 cm2)
2.2 dpm/cm2 other alpha emitters (66,000 dpm/300 cm2)
Labels removed or defaced and “Empty” label applied
Proper UN ID# marked on package

91. Requirements for LSA and SCO 49 CFR 173.427
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

92. Conveyance

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

94. Carriage by Public Highway

95. Carriage by Public Highway
Packages labeled White I, Yellow II, or Yellow III cannot be carried in compartments occupied by passengers (except couriers) - 49 CFR (c)
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

96. Driver Training 49 CFR 177.816 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

97. Shipping Papers 49 CFR
Carrier may not accept HAZMAT without shipping papers (unless excepted)
Must be certified by the shipper
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
It is prudent to hand the shipping papers to the driver separate from the package

98. Contamination of Vehicles 49 CFR 177.843
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)
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

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

100. Receiving and Opening Radioactive Material Packages

101. Receiving Packages
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

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

103. Receiving Packages 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 71.47
Must have written procedure for package opening and assure that it is followed

104. Safety Training 49 CFR 172.704(a)
Emergency Response
Measures to protect the employee
Methods for avoiding accidents

105. Emergency Response Notify final carrier and NRC if:
Radiation level greater than 200 mrem/hr on package surface
Contamination - averaged over 300 cm2
>220 dpm / cm2 beta/gamma, low toxicity alphas
>22 dpm / cm2 other alphas

106. Immediate Notification of DOT Required by Carrier 49 CFR 171. 15 and
Persons killed
Injuries requiring hospitalization
Carrier or other property damage >$50,000
Evacuation of general public > 1 hour
Major transportation artery shutdown for > 1 hour
Flight pattern or routine of aircraft is altered
Fire, breakage, spillage or suspected radioactive contamination involving Class 7 shipment

107. Immediate Notification of DOT Required by Carrier 49 CFR 171. 15 and
Notice shall be given to DOT
Notice involving aircraft made to FAA
Notice involving etiologic agents made to CDC
Info required using DOT Form F
49 CFR (b)

108. Immediate Notification of DOT Required by Carrier 49 CFR 171. 15 and
Written follow-up required in 30 days
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

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

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

111. Hazardous Materials Security New Regulations
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

112. HazMat Security Plan New - Subpart I 172.800
Required for those offering HazMat for transportation in commerce
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

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

114. DOT Inspections & Fines

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

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

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

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

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

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