{"operation":"document","citation":"06-0153","title":"Air Force Medical Operations Agency — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2006-09-05","effective_on":null,"summary":"06-0153 response to Air Force Medical Operations Agency concerning 173.443.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0153.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0153.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0153","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2006/060153.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\n400 Seventh Street, S.W.\nWashington, D.C. 20590\nMaterials Safety Administration\nPipeline and Hazardous\nSEP - 5 2006\nMr. Mark C. Wrobel\nRef. No.: 06-C153\nChief, Radiation Protection Division\nSecretariat, Air Force Radioisotope Committee\nAir Force Medical Operations Agency\nOffice of the Surgeon General\n110 Luke Avenue, Room 405\nBolling AFB, DC 20032-7050\nDear Mr. Wrobel:\nThis is in response to your letter dated June 12, 2006, requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) pertaining to the\ncontamination control requirements for Class 7 (radioactive) materials under § 173.443.\nSpecifically, you ask for a wipe test waiver to be granted to the U.S. Air Force for Chemical\nChemical Agent Detector Alarms (ACADAs). You have also referenced and enclosed a letter\nAgent Monitors (CAMs), Improved Chemical Agent Monitors (ICAMs), and Automatic\nof interpretation from Hattie Mitchell to Vernon Vonders (Ref. No.: 99-0119) that clarified §\n173.443 in regards to the degree of flexibility of contamination control.\nSection 173.443 states that \"The level of non-fixed radioactive contamination may not exceed\nthe limits set forth in Table 9 and must be determined by either:\n(1) Wiping an area of 300 square centimeters of the surface concerned ...; or\n(2) Alternatively, the level of non-fixed radioactive contamination may be determined\nby using other methods of equal or greater efficiency.\"\nSections 173.443(a)(1) and 173.443(a)(2) continue to allow a shipper the same degree of\nflexibility. The shipper must either make one or more wipe measurements and compare the\nresults against the limits in Table 9, or use another method of equal or greater efficiency. As\nused in § 173.443(a)(2), \"efficiency\" represents the ratio of a measured value of\ncontamination (such as from a wipe) divided by the actual contamination on the surface of the\npackage, or, in a more general sense, an alternate method which gives the same or greater\nassurance that the package contamination levels do not exceed the stated regulatory limits. If\nmaterial which is protected from on-site contamination, it is acceptable as long as it ensures\na shipper utilizes methods which do not rely on actual wipe samples, such as new packaging\ncompliance.\n173.443\n060153\n\n<<<PAGE 2>>>\n\nI hope this information is helpful. Should you have further questions, please contact us.\nOffice of Hazardous Materials Standards\nSenior Transportation Specialist\n\n<<<PAGE 3>>>\n\nDEPARTMENT OF THE AIR FORCE\nBAHt\nHEADQUARTERS UNITED STATES AIR FORCE\nWASHINGTON DC\n$173.443\nContamination Control\n06-0153\n12 June 2006\nMEMORANDUM FOR OFFICE OF US DEPARTMENT OF TRANSPORTATION\nRESEARCH AND SPECIAL PROGRAM ADMINISTRATION\nFROM: AFMOA/SGPR\nBolling AFB, DC 20032-7050\n110 Luke Avenue, Room 405\nSUBJECT: Request for Wipe Test Waiver for Chemical Agent Monitors (CAMs) and Detectors (CADs)\nswipe testing of packages prior to shipment for US Air Force CAMs and CADs when new packaging is\nThe US Air Force requests a waiver from Department of Transportation (DOT) requirements for\nused. DOT regulation 49 CFR 173.443 stipulates limits on non-fixed (removable) radioactive\ncontamination limits set in Table 11 are applicable to excepted packages for limited quantities of Class 7\ncontamination on the external surfaces of each package offered for transport (Table 11 of 173.443). The\nradioactive materials (173.421) and for radioactive instruments and articles (173.424), and are\ntraditionally confirmed by performing a swipe test on the packages surface. At present, the US Air Force\nhas a large inventory of Chemical Agent Monitors (CAMs), Improved Chemical Agent Monitor\n(ICAMs), and Automatic Chemical Agent Detector Alarms (ACADAs) for which the waiver is requested.\naccordance with the devices sealed source and device registry. Use of new packaging to ship these\nThese devices each contain 15 mCi Ni-63, for which annual leak tests are not required in\nwould support US Air Force mission critical activities, and save considerable time and effort, without risk\ndevices would provide high assurance that the criteria of 49 CFR 173.443 are met. Granting this waiver\nto AF personnel or the public. The attached letters from the US Army to DOT, 4 May 99, and from DOT\nto the US Army, 10 Jun 99, provide an identical waiver for wipe tests of shipping packages when.new\nICAMs and ACADAs. If you have any questions or need further input, then please contact Dr. Ram Bhat\npackaging materials are used. We request a similar waiver for U.S. Air Force shipments of CAMs,\nat 202-767-4306 or e-mail at ramachandra.bhat@pentagon.af.mil. Our telefax is 202-404-8089.\nChief, Radiation Protection Division\nMARK C. WROBEL, Lt Col, USAF, BSC\nSecretariat, Air Force Radioisotope Committee\nAir Force Medical Operations Agency\nOffice of the Surgeon General\n2 Attachments\n2. US DOT Research and Special Program Administration Memo, 10 Jun 99\n1. US Army TAACOM Memo, 4 May 99\nAFMC/LSO/LOT (Mr. Werneke)\nItem Manager (Mr. Inglet)\nIrammis\\rammis\\SGZRIFILE PLAN14 POLICY\\4-04 DOT\\R020060612","truncated":false,"body_characters":5098}