American Airlines — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Department 400 Seventh St., S.W. Washington, D.C. 20590 Research and ›pecial Program: idministratior OCT 2 2002 Mr. Les Adolph American Airlines Ref. No.: 02-0152 P.O. Box 582809 MD 517 3900 North Mango Road Iulsa, OK 74116 Dear Mr. Adolph: you are required to check each UN2910 or UN2911 radioactive This is in response to your May 30, 2002 letter inquiring whether material shipment under § 173.424 (d) of the Hazardous Materials 6 52 04 shipments consist of radioactive articles, such as exit signs, Regulations (HMR; 49 CFR Parts 171-180). You state that the fuel flow emitters and smoke detectors and that you have their radioactive readings from the manufacturers. Section 173.424 (d) states, in r article and its packaging is excepted from the specificatior part, that a radioactive instrument requirements if: packaging, shipping paper and certification, marking and labeling external surface of any unpackaged instrument or article The radiation level at 10 cm (4 in) from any point on the does not exceed 0.1 mSv/hour (10 mrem/hour). but do not state how to ascertain whether the levels are within The HMR specify the radiation level limits that must be achieved the acceptable limits. means you deem appropriate to assure that your UN2910 or UN2911 radioactive material shipments do not exceed the limits specified in $ 173.424 (d), including the usage of radioactive information received from the articles' manufacturers. should be exercised when manufacturer's data is used to assess However, caution for damage. instruments or articles which are not new due to their potential I hope this information is helpful. Sincerely, Hothe 2. Mithell Hattie I. Mitchell Chief, Office of Hazardous Materials Standards Regulatory Review and Reinvention 173.424ld) 020152#

Page 2Betts 3173.424 (d) Betts, Charles Packages RAM From: To: ent. Mazzullo, Ed 02-0152 Subject: reated differently under ICAO: Please develop a response. Looks like we totally except these materials. Are they From: Les Adolph [mailto:Les.Ado1ph@aa.com] --Original Message-. ent: Thursday, May 30, 2002 Ed <RSPA> 9:17 AM So: Mazz Lar FacaRion questior Ed, I've had some discussions with Frits and Duane Pfund, when Duane was in Tulsa for the SÜN2910 and(2911) as detailed in 173.424 (d)? I have an email from Frits that I could ATA COMAT meeting on whether we needed to check each xadioactive material shipment under produce if wel were ever questioned sort of negative spot. (I value all of the friendships and relationships I have with all by the FAA but I would not want to put Frits in any Frits indicated\to me, the radiation would get weaker rather than stronger... These items of you!!) We have the radioactive readings from the Manufacturer for these units and as smoke detectors, so as you can see, vould be like the exit signs, some fuel flow emitters, some of the instrumentation and the I need to request la formal clarification or do you think we can just assume everyone knows all are very low level itens.... What do you think, do you all but it seems like that we are doing the right thing in recently if I think there is a chance of it happening, the FAA compliance with the regs.?? I hate too keep bothering keeps coming thru fot me!! H!!! Les Best regards, Use this#

Page 3Betts, Charles From: Sent: Les Adolph [Les.Adolph@aa.com] Subject: To: ednesday, August 07, 2002 9:42 A Re: Letter of Clarificaton etts, Charles <RSPA Thanks, Les Mr. Adolph, >>> "Charles Betts" <Charles.Betts@RSPA.dot.gov> 08/07/02 08:34AM >>> I am currently working on your request for a letter regarding radioactive material shipment under UN2910 and UN2911 as described of clarification whether it concerns "shipments onboard the aircraft" or in § 173.424 (d) • However, after reading your e-mail request, I am unclear installed/used onboard the aircraft." Could you please help to clarify this Regards, Charles.....#