1. CTMA 2015 HM-250 and HM-215M Update
Regulatory Changes from DOT

2. Dates to Remember Final Rule HM-250 Final Rule HM-215M
Published on July 11, 2014
Effective Date: October 1, 2014
Delayed Compliance Date: July 13, 2015
Final Rule HM-215M
Published on January 8, 2015
Effective Date: January 1, 2015
Delayed Compliance Date: January 1, 2016

3. Which is Which?
HM-250
HM-215M
Final Rule that primarily harmonizes with 2009 IAEA TS-R-1 for the transportation of radioactive materials
Final Rule that harmonizes with the international standards (ICAO and IMDG) mainly for non-radioactive requirements

4. 173.401(b)(4) and (5) Scope When is radioactive material not Class 7?
Modified language in paragraph (b)(4) concerning naturally occurring radionuclides
Added a new paragraph (b)(5) establishing that objects with contamination are not regulated if levels do not exceed the definition of contamination in

5. Definitions in 173.403 Contamination – minor wording changes
Criticality Safety Index – added “conveyance”
Exclusive Use – can only use when required
Fissile Material – clarified and added reference to the exceptions in

6. Definitions in 173.403 Low Specific Activity Radiation Level
Mainly revised for clarity
Non-fissile or fissile excepted in the opening paragraph
Radiation Level
Clarifies that it is the sum of all types of ionizing radiation present

7.
Revisions to the requirements for calculating A1 and A2 values for unlisted radionuclides
Added “or no relevant data…” in (b) to help us with using the Tables
Rewording of (c) has some unintended consequences
Corrected references for symbols in (d)
Radioactive contents in Table 7 has been reworded to more closely align with the TS-R-1

8. Limited Quantity
Formatting changes: re-designation of the paragraphs
Unfortunately these are not properly referenced in the following sections:
SP 369
173.4(b)
(a)(2)
(c)
(a)

9. New Proper Shipping Name
UN3507 Uranium Hexafluoride, Radioactive Material, excepted package Class 8 (7)
Only for 0.1 kg or less Uranium Hexafluoride
Must meet the requirements for Ltd. Qty
Ripple effects:
Addition of Special Provision 369
Minor changes to 173.2a
Changes to (d)

10. Packaging General Design Requirements in 173.410
For air shipments, internal pressure differential is not less than maximum normal operating pressure + 95 kPa
Industrial Packages in
Clarifies the use of portable tanks in (b)(4)
Clarifies the use of cargo tank/tank car in (b)(5)
Revised 1 year document retention to 2 years in (c)

11. Type A Packaging
(f) pressure changed from 25 kPa (3.6 psi) to 60 kPa (8.7 psia)

13. Type A Packaging
(a)
Revision of the document retention period from 1 year to 2 years (after January 1, 2017)
Rewritten to describe (at length) the two options for document retention
Full description of packaging and testing or
Certification from the packaging manufacturer

14. LSA/SCO Transport Requirements 173.427(a)
For Exclusive Use LSA/SCO (a)(6)
The “shipment” must be placarded (instead of the “transport vehicle”)
Removed the placarding exception for uranium and thorium ores
Subsidiary hazard labels required (even though primary label is not)

15. LSA/SCO Transport Requirements 173.427(b)
Paragraph (b)(5)
Portable Tanks, Cargo Tanks, Tank Cars meeting the requirements for Type IP-1 can be used as Type IP-2 or Type IP-3 ( )
Not limited to LSA-I liquids
No longer required to be exclusive use
References to DOT tanks removed

16. LSA/SCO Transport Requirements 173.427(c)
Paragraph (c)(4)
New paragraph requiring placarding for all unpackaged LSA-I/SCO-I by highway and rail

17. LSA/SCO Transport Requirements 173.427 Tables
New third column for inland waterway conveyance limits
Table 6
Added “Type” to all IP descriptions

18. Excepted Package Marking 173.422(a)(2)
RQ for any non-bulk excepted package containing a hazardous substance

19. Specification Marking 172.310(b)
Package Type
Marking size requirement 12mm (0.47 inches)
Type IP-1, Type IP-2, Type IP-3
Type A
Type B(U), Type B(M)

20. Overpack
HM-250 added that overpacks containing radioactive packages must be marked with the word “OVERPACK”
HM-215M removed the radioactive packages (inadvertently?) but added a minimum size requirement of 12mm (0.5 inches) high

21. Radioactive Label
Maximum activity of the radioactive contents during transport (g)(2)

22. LSA/SCO Subsidiary Label
Although excepted from radioactive labels (for the primary hazard), LSA/SCO exclusive use must be labeled for any subsidiary hazards per (a)(6)(vi)
Ripple effect: subsidiary hazard will now be required as a shipping paper entry

23. Shipping Papers 172.203(d) Additional description requirements
“Special Form” if not already in the proper shipping name
Maximum activity of the radioactive contents during transport
Label category does not require “RADIOACTIVE”

24. 172.504 Placarding Radioactive placards are required on
Packages with Yellow-III labels
All shipments of unpackaged LSA-I/SCO-I
All exclusive use shipments in
All exclusive use shipments in
All exclusive use shipments in
Closed vehicles used in accordance with (d)

25. Contamination Control 173.443
This section previously addressed only external contamination on a package
Now included is the external surface on a
Package
Conveyance
Freight container
Overpack
Plus the internal surfaces when used to transport inner packages

26. Contamination Control 173.443 (a)
All contamination must be kept As Low As Reasonably Achievable (ALARA)
Levels may not exceed Table 9 EXCEPT for
Equipment dedicated to transport unpackaged material in accordance with (c) and
Remain under that specific exclusive use
Non-exclusive use shipments are not required to be surveyed unless contamination is suspected

27. Contamination Control 173.443 (a) and (b)
Table 9 Limits: Corrected the conversion from bq/cm2 to dpm/cm2 using SI units instead of customary units
Reworded (b): Still allows for 10 times Table 9 limits during transport and must be exclusive use (“weeping” condition)

28. Contamination Control 173.443 (c)
Each conveyance, overpack, freight container, tank or IBC used as exclusive use under the following conditions must be surveyed with appropriate radiation detection instruments after each shipment:
(b) the “weeping” condition
(b)(4) LSA/SCO, <A2, in excepted packaging
(c) unpackaged LSA-I and SCO-I

29. Contamination Control 173.443(c)
The survey must show that non-fixed contamination meets (a)
ALARA
Does not exceed Table 9 limits
The radiation level at each accessible surface is ≤ 0.5 mrem/hr

30. Contamination Control 173.443(c)
Meeting these survey requirements ONLY allows for continued exclusive use of the equipment as one of the following:
(b) the “weeping” condition
(b)(4) LSA/SCO, <A2, in excepted packaging
(c) unpackaged LSA-I and SCO-I

31. Contamination Control 173.443(c)
The ONLY way to utilize the aforementioned exclusive use shipment types for non-exclusive use or general service is:
Perform decon on the equipment as necessary and
Any contamination is determined to be below the limits in (b)(5) and below the definition of contamination in

32. Contamination Control 173.443(d)
“Sole Use” allows up to 10 times the Table 9 limits for vehicles used under the following conditions
Exclusive use by highway or rail
Survey of interior surfaces of empty vehicle
≤ 10 mrem/hr surface
≤ 2 mrem/hr at 1 meter
“For Radioactive Materials Use Only” stenciled
Kept closed (except for loading and unloading)
Placards required

33. Contamination Control 173.443(e)
New paragraph for leaking or suspect packages
Restrict access
Assessment of the contamination must include
The package
The conveyance
Adjacent loading/unloading areas
All other materials carried on the conveyance
Protect persons, property, environment
Not forwarded until repaired/decontaminated

34. Contamination Control
Added similar language for surveys and re-use to all modes of transport
Carriage by Rail in
Carriage by Aircraft in
Carriage by Vessel in
Carriage by Public Highway in

35. HM-215M : “Timing is Everything”
Important to note:
Because this rule was published AFTER October 1, 2014 it is not in the current 49 CFR (unless you use regulations that are updated quarterly)
This Final Rule must be consulted in addition to the current 49 CFR if you are complying with HM-215 in 2015 and especially after January 1, 2016

36. Definitions 171.8 New or revised Absorbed gas Bundle of cylinders
Large salvage packaging
Neutron radiation detector
Non-bulk packaging
Radiation detection system

37. 171.23(b)(11)
Requirements for specific materials transported under ICAO, IMDG, TDG or IAEA
Fissile excepted materials must meet IAEA SSR-6 regulations and

38. Proper Shipping Names Ten shipping names were removed
Dozens have been added
Pages and pages of entries were revised
Largely due to changes in Column 10 for IMDG harmony

39. List of Marine Pollutants
Addition of 62 new entries
New exception for 5 liters (liquids) and 5 kg (solids) if regulated only because they are a marine pollutant

40. Special Provisions 172.102 Safety devices (automotive parts)
Neutron Detectors
Absorbed gases
Paint/paint related material in same package
Uranium Hexafluoride
IBC Codes

41. Shipper’s Certification
Above = Below
“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.”
Note: In the certification the word “above” may be substituted for the word “below” as appropriate.

42. Exceptions for Light Bulbs 173.11
No other requirements if:
1 g or less of hazardous material per bulb
30 g or less of hazardous material per package
Each bulb in separate inner packaging
Strong tight outer (173.24(b))
Capable of passing a 1.2 m (4 foot) drop test

43. Explosives Table of Packing Methods
Changes to some packing methods
Always consult the table

44. Lithium Cells and Batteries 173.185
Added Large Packaging requirements
Allows for the Cargo Aircraft Only Label to substitute for the lithium battery marking

45. Questions?
Thank You