{"operation":"document","citation":"06-0158","title":"Troxler Electronic Laboratories, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2006-08-08","effective_on":null,"summary":"06-0158 response to Troxler Electronic Laboratories, Inc. concerning 173.475.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0158.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0158.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-06-0158","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2006/060158.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Department\nWashington. D.C. 20590\n400 Seventh Street, S. W\nPipeline and Hazardous\nMaterials Safety Administration\nAUG - ≥ 2000\nMr. Steve Browne\nRef. No.: 06-0158\nTroxler Electoronic Laboratories, Inc.\n12057 Research Triangle Park\nNorth Carolina, 27709\nDear Mr. Browne:\nThis is in response to your July 18, 2006 letter requesting clarification of the Hazardous\n(radioactive) materials. Specifically, you ask if the radiation level on the external\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to Class 7\nsurface of a package containing a portable nuclear gauge is required to be measured\nprior to each shipment.\nThe answer is no. In accordance with § 173.475, before each shipment of any Class 7\n(radioactive) material package, the offeror must ensure that external radiation and\ncontamination levels are within the allowable limits specified by the HiMiR. Section\nshipment; however, each offeror of a Class 7 (radioactive) material must perform\n173.475 does not specifically require the radiation level to be measured prior to each\nappropriate examinations or tests to ensure that the external radiation and\nselect an appropriate examination or test method. Alternative examinations and test\ncontamination levels are within the allowable limits. It is the offeror's responsibility to\nmethods are authorized to the extent they ensure compliance with the external radiation\nand cortamination limits authorized by the HMR.\nto contact this office.\nI hope this information is helpful. If you have further questions, please do not hesitate\nSincerely,\nJohn A. Gale\nOffice of Hazardous Materials Standards\nChief, Standards Development\n173.415\n060158\n\n<<<PAGE 2>>>\n\nEicherlaub\nPage 1 of 1\n$173.475\nWilliams, James <PHMSA>\nRAM\nFrom: Steve Browne [sbrowne@troxlerlabs.com]\n06-0158\nSent:\nTuesday, July 18, 2006 2:22 PM\nTo:\nWilliams, James <PHMSA>\nSubject: Fw: Interpretation of 173.475\n---- Original Message --.\nFrom: Steve Browne\nSent: July 05, 2006 11:29 AM\nSubject: Interpretation of 173.475\nJim,\nradiation survey to ascertain the TI value prior to each and every shipment. I would like to get\nRecently an FAA inspector (Louis Fernandez) told a Troxler portable nuclear gauge user that they must perform a\nU.S.DOT's interpretation of section 173.475 which states:\nexamination or appropriate tests, that external radiation and contamination levels are within the allowable\nBefore each shipment of any Class 7 (radioactive) materials package, the offeror must ensure, by\nlimits specified in this subchapter.\nTroxler ships thousands of portable gauges containing sealed sources per year. However, we: do not make a\nradiation measurement on each gauge package before shipment. Instead, the Transport Index is determined\nonce for each model gauge. That value is documented in the NRC certificate of registration for the gauge and\nthe package and entered on the shipping papers. Because all units of a given model contain the same type of\nalso in the Troxler gauge operation and instruction manual. That value is then marked on the radioactive label or\nsources producing the same radiation levels, there is no need to remeasure the radiation level unless the source\nexamination of the gauge prior to shipment, which I believe satisfies 173.475. If this interpretation is not correct, it\nhousing, shielding, or shutter malfunction or have been damaged. This can be ascertained through a visual\nwill have far reaching ramifications.\nshipments (via air or ground).\nseemed to make a distinction between private carrier shipments (to and from job sites) and common carrier\nanswer both from the standpoint of being a nuclear gauge shipper and of being a nuclear gauce manufacturer to\nI would appreciate getting U.S.DOT's interpretation of section 173.475. It is very important for Troxler to know the\nwhom customers turn to for correct hazmat shipping advice. Please let me know if you have any questions.\nRegards,\nCorporate Radiation Safety Officer\nSteve Browne\n(919) 485-2228 voice\nTroxler Electronic Laboratories, Inc.\n(919) 485-2250 fax","truncated":false,"body_characters":4071}