Airgas, Inc — Hazardous Materials Safety Interpretation

Page 1FEB 27 2006 Mr. Randy Porter Ref. No.: 05-0310 7000 East Avenue Airgas, Inc. Livermore, CA 94551 Dear Mr. Porter This is in response to your letter requesting clarification of the packaging and marking requirements for the transportation of radioactive materials under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You indicate that you are shipping a Type A quantity of non-fissile radioactive material in a Type B package. In order to make the shipment you may: 1. Use a Type B packaging for the transportation of a Type A, or A2 quantity of material (§ 173.415(c)). However, you must select a proper shipping name indicating that the material is in a Type B packaging. In addition, you should include the isotope on the shipping paper and an indication that the Type B packaging contains a Type A quantity of material; or 2. Use a Type B packaging as a Type A packaging. This requires you to convert a Type B packaging to a Type A packaging by removing or covering all markings (including the specification plate) used to indicate that it is a Type B packaging and replacing them with the appropriate Type A markings. In addition, the Type A packaging is a new design and must be certified as meeting the Type A requirements. I hope this information is helpful. Please contact us if you require additional assistance. Sincerely, Pin too at Chief, Standards Development Office of Hazardous Materials Standards 173.415(8). 050310#

Page 20E/RL-96-57, Vol. 1, Chapter 1.0, 1.4 Use uf Type B packaging states Identification markings should be covered and new marking ("USA DOT-7A TYPE A" and "radioactive material") affixed the package, pursunt to 49 CFR 173.415(a). Is this the correct method for my shipment? Thank you Randy Porter porter4@llnl.gov (925) 422-5994 7000 East Ave Livermore, CA. 94551#