Troxler Electronic Laboratories, Inc. — Hazardous Materials Safety Interpretation

Page 1400 Seventh St., S.W. Washington, D.C. 20590 pecial Program: research and Administration MAR 2 6 2002 Mr. Stephen A. Browne Corporate Radiation Safety Officer Ref. No. 02-0058 Troxler Electronic Laboratories, Inc. Box 12057 Research Triangle Park, NC 27709 Dear Mr. Browne: This is in response to your November 13, 2001 letter concerning radioactive packaging requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). We apologize for the delay in responding to your letter due to mail delivery problems many Federal agencies have been experiencing because of screening and decontamination precautions. Specifically, you request clarification on whether cracks which penetrate the full depth of the wall (either radioactive material would be in violation of the regulations. You cite § 173.475(b) which states that inner or outer) of a shipping case designed to transport scientific gauges containing special form packaging required to transport these gauges must be ".. in unimpaired physical condition, except for superficial marks." You state that these cracks do not meet the requirements in this section. Your opinion is correct. The cracks in the shipping case described in your letter compromise the physical integrity of the packaging, increasing the chance that the packaging could fail during incidents normal to transportation. Scratches and scuffs are examples of surface marks that would not compromise the physical integrity of the packaging and would be considered "superficial marks." I hope this satisfies your request. Sincerely, Deln Delmer F. Billings Chief, Standards Development Office of Hazardous Materials Standards ANNALI HI 173.475(6) 020058#

Page 2Johnsen TROXLER 8173. 475(b) November 13, 2001 RAM Mr. Edward T. Mazzulo !!! i Director, Office of Hazardous Materials Standards 1:10 -71 02-0058 400 7th Street S.W. U.S. DOT/RSPA (DHM 10).. ^ Washington, D.C. 20590000... 1C Dear Mr. Mazzullo: I am writing to request clarification on the quality control requirements in 49 CFR 173.475(b) for packages containing splaar forma quai. Troxier manufactures and repairs portable moisture density gauges Type A package requirements The shipping cases are injection-molded plastic, double-walled construction weas. Thu gaugts at snipped in reusable shipping cases that Tett with an air void between the inner and outer walls (see enclosure 1 for photo of a typical shipping case and gauge). Customers periodically ship gauges to Troxler for calibration and repair. Before returning a gauge to a 10%) develop cracks in the inner wall where the weight of the equipment rests most heavily (see enclosure customer, the shipping casc is inspected in accordance with §173.475: Over time, some shipping cases (5- 2 for photo of a typical crack). Troxier considers a shipping case with any cracks to be defective, regardless of whether the crack is on the inner or outer wall, since the body of the case is a single, molded return their gauge. picce. In these situations, we advise the customer that the shipping case must be replaced before we can Some customers have challenged the need to replace the shipping case, arguing that the package is material during shipping. unimpaired because, based on experience; the cracks do not affect the containment of the radioactive We agrec that loss of radioactive material containment is unlikely, however, according to 173.475(b), the cracks which penctrate the full depth of the wall (either inner or outer) are more than superficial marks, package must be in unimpaired physical condition, except for superficial marks. Our interpretation is that -thus the package does not meet the standard. We want to comply with DOT requirements, but we do not want to force customers to purchase new quality control inspection criteria in $173.475(b) is correct or not in this situation. shipping cases unnecessarily. Therefore, we would like clarification on whether our interpretation of the Sincerely, Stephen A. Browne Corporate Radiation Safety Officer Enclosures (2) Troxler Electronic Laboratories, Inc Box 12057 + 3008 Cornwallis Road • Research Triangle Park, North Carolina 27709 Tel: (919) 549-8661 • Fax: (919) 485-2250 + e-mail: troxrso@troxlerlabs.com#