{"operation":"document","citation":"04-0047","title":"Northrop Grumman Electronic — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2004-03-30","effective_on":null,"summary":"04-0047 response to Northrop Grumman Electronic concerning 173.443.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0047.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0047.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0047","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2004/040047.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\n400 Seventh St., S.W.\nSpecial Programs\nResearch and\nWashington, D.C. 20590\nAdministration\nMAR 3 0 2004\nMr. Steven McKew\nManger, Compliance Engineering\nRef No.: 04-0047\nNorthrop Grumman Electronic\nP. O. Box 746, Mail Stop 1401\nBaltimore, MD 21203\nDear Mr. McKew:\nThis is in response to your letter dated February 25, 2004, concerning the requirements for measuring\nlevels of radioactive contamination on the external surfaces of packages of radioactive material offered\nfor transportation under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-181).\nSection 173.443(a) requires the level of non-fixed (removable) radioactive contamination on the\nexternal surfaces of a package offered for transportation to be kept as low as reasonably achievable.\nThe HMR prohibit the non-fixed radiation contamination to exceed the limits set forth in Table 11 and\nauthorize the use of a wipe survey or other assessment method to check for non-fixed radioactive\ncontamination. The use of wipes is a suggested technique; however, there is no specification for the\ntype of instrument to be used to measure the amount of activity on the wipe. The regulations permit\nother methods to be used to assure that contamination is within acceptable limits. The HMR provide\nshippers considerable flexibility to determine the most appropriate method among recognized\nprocedures to achieve the performance standard.\nI hope this information is helpful. Please contact us if you require additional assistance\nSincerely,\nChief, Regulations Development\nOffice of Hazardous Materials Standards\n173.443\n040047\n0: 2600т.\"\n\n<<<PAGE 2>>>\n\nRelertova\n$173.443\nRAM\n04-0047\nNORTHRO, GRUMMAN\nElectronic System\nFebruary 25, 2004\nMr. Edward T. Mazzullo\nDirector, Office of Hazardous Materials Standards\n400 7' Street, S.W.\nResearch and Special Programs Administration\nWashington, D.C. 20590-001\nradioactive material (HMR; 49CFR Part 173.44)\nSubject: Clarification concerning contamination control of external packages containing\nDear Mr. Mazzullo,\nNorthrop Grumman Electronic Systems has historically shipped an electronic component that\ncontains trace quantities of a radioactive isotope. We currently ship this as \"Radioactive\nmaterial, excepted package-instruments or articles, UN2911\"\nOur manufacturing process takes a small glass ampule slightly larger than the size of your\naverage pill capsule. This ampule has a trace amount of radioactive material sealed inside what\nwe deem an electronic tube. Once sealed, we wipe/smear and ensure no external contamination\nelectronic tube connected to additional electronics and further encased within a sealed metal\nexists on the external surface of the ampule/tube. Our manufacturing process then has the\nhousing. At this point in the manufacturing process, the external surfaces are again smeared to\nensure there is no external contamination on the surface of the sealed metal housing. As a\n, VCR tape. At this level of assembly, all requirements for labeling are verified, and there is a\neference, once it is incorporated in the larger assembly, the approximate size of the unit is that of\nzero radiation reading on all surfaces. The unit is then cleared by our radiation safety procedures\nas to not posing any handling hazard, not possessing any surface contamination, and not having\nany surface readings.\nAt this point the unit is moved to the shipping department for transportation to another facility\nfor incorporation into a larger electronic component.\n\n<<<PAGE 3>>>\n\nPage 2\nMy question involves our interpretation of 49CFR 173.443, and if that interpretation would\nrequire wipe testing of the surface on the box being shipped to our other facility, or can we utilize\nof contaminated pete. our operatio at the to previous there ts che surpain cos minicatio at\nt contamination control. Our operational\nto ensure the unit never leave the manufacturing area with any reading of radioactivity, and\ntwo key manutacturing points, and then release the sealed unit as free and clear. Our approach is\nalways with zero surface contamination, fixed or smearable. I liken this analysis to that of smoke\ndetectors, and a case of detectors being readied for shipment.\nI greatly appreciate your assistance in this manner, and look forward to your response.\nSteven McKew\nManager, Compliance Engineering\nNorthrop Grumman Electronic Systems\nP.O. Box 746, Mail Stop 1401\nBaltimore, MD 21203\nPh (410) 993-8940\nFx (410) 993-2753\nCell (410) 227-6399","truncated":false,"body_characters":4494}