09-0110
09-0110
Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave, S.E. Washington, D.C. 20590 JUN 1 7 2009 Mr. Roy A. Parker, Ph. D. Radiation Physics Consutant FedEx Express 5061 Abelia Drive Baton Rouge, Louisiana 70808 Ref. No. 09-01 10 Dear Mr. Parker: This responds to your May 5,2009 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 1 7 1 - 1 80). Specifically, you ask if the following descriptions are acceptable for describing the package type on a shipping paper for Class 7 (radioactive) materials: Excepted Package Industrial Package Type A Package Type B Package The answer is yes. Section 172.202(a)(7) requires the number and type of packages to be indicated on a shipping paper. It is the opinion of this office that the descriptions that you provided in your email are acceptable for describing the type of package on a shipping paper for Class 7 (radioactive) materials. I hope this information is helpful. Please contact us if you require additional assistance. Sincerely,, I hales E. Betts Standards Development Office of Hazardous ate rials Standards#
Page 2From: Roy A. Parker [roy@royparker.org] Sent: Friday, May 08, 2009 3: 17 PM To: ~ e t t s i ~harles <PHMSA> Cc: David Littlejohn Subject: Request for Interpretation 49 CFR 173.202(a)(7) P 5hipp70g y e r s Importance: High Attachments: Roy Parker.vcf 09- 01 I0 Roy Parker.vcf (671 6) Charles, Pursuant to our telephone conversation please clarify for radioactive materials (Class 7) shipments that Excepted Package, Industrial Package, Type A package and Type B package are valid descriptions for type of package in accordance with 49 CFR 173.202(a)(7) and that such descriptions as drum, fiberboard box and cylinder are not required on shipping papers. Regards, Roy A. Parker, Ph.D. Radiation Physics Consultant FedEx Express#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.