RSB Logistic — Hazardous Materials Safety Interpretation

Page 1Bruce Natske RSB Logistic 219 Cardinal Crescent Saskatoon, SK S7L 7K8 Canada Reference No. 17-0131 Dear Mr. Natske: This letter is in response to your November 28, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the labeling and placarding requirements for radioactive materials. Specifically, you ask whether the transport · index (TI) of the flat-rack container in the photograph ( considered an overpack for purposes of the HMR) you provided can be measured by taking the sum of the TI of the packages contained therein. The answer is yes. In accordance with§ 172.403(h)(3) and Section 5, Paragraph 524 of the International Atomic Energy Agency (IAEA) Regulations, the measurement of the TI for the flat-rack container may be done by either using the TI sum of each package, or by direct measurement. With regards to the hazard communication requirements, in accordance with § 171.26, a Class 7 (radioactive) material being imported into or exported from the United States or passing through the United States in the course of being shipped between places outside the United States may be offered for transportation or transported in accordance with the IAEA Regulations. Furthermore, Section V, Paragraph 543 of the IAEA Regulations states that, instead of using both labels and placards, it is permitted, as an alternative, to use enlarged labels only, where appropriate, as shown in Figures 2-4, except having the minimum size shown in Figure 6. Therefore, the flat-rack container shown in the photograph provided may display an enlarged ''RADIOACTIVE YELLOW-III" label. I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, PHA-10 INITIALS Yt\~N DATE ROUTING ~\\{;-\ 0 1N1T1A~ t , is .fJ ~fl.ii 1 DATE l\/\\ /I~ INITIALS Dirk Der Kinderen Chief, Standards Development Branch Standards and Rulemaking Division DATE#

Page 20 U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 rlAY O 1 2019 Bruce Natske RSB Logistic 219 Cardinal Crescent Saskatoon, SK S7L 7K8 Canada Reference No. 17-0131 Dear Mr. Natske: This letter is in response to your November 28, 2017, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the labeling and placarding requirements for radioactive materials. Specifically, you ask whether the transport index (TI) of the flat-rack container in the photograph (considered an overpack for purposes of the HMR) you provided can be measured by taking the sum of the TI of the packages contained therein. The answer is yes. In accordance with§ 172.403(h)(3) and Section 5, Paragraph 524 of the International Atomic Energy Agency (IAEA) Regulations, the measurement of the TI for the flat-rack container may be done by either using the TI sum of each package, or by direct measurement. With regards to the hazard communication requirements, in accordance with § 171.26, a Class 7 (radioactive) material being imported into or exported from the United States or passing through the United States in the course of being shipped between places outside the United States may be offered for transportation or transported in accordance with the IAEA Regulations. Furthermore, Section V, Paragraph 543 of the IAEA Regulations states that, instead of using both labels and placards, it is permitted, as an alternative, to use enlarged labels only, where appropriate, as shown in Figures 2-4, except having the minimum size shown in Figure 6. Therefore, the flat-rack container shown in the photograph provided may display an enlarged "RADIOACTIVE YELLOW-III" label. I hope this information is helpful. Please contact us if we can be of further assistance. ~;?7;7Z{ ~k~~n Chief, Standards Development Branch Standards and Rulemaking Division#

Page 3Dodd. Alice (PHMSA) From: Sent: To: Subject: Attachments: Jones, Breanna CTR (PHMSA) Friday, December 01, 2017 3:45 PM Hazmat Interps FW: Class 7 Transportation Index (Tl) Class 7, UN 2977, UF6 Marine shipment (RSB Logistic. DOT 266723) 2977SIDE.JPG Hello, Please see the interp request below and attached. Regards, -Breanna From: Bruce Natske [mailto:Bruce.Natske@rsblogistic.com] Sent: Tuesday, November 28, 2017 12:15 PM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Subject: RE: Class 7 Transportation Index (Tl) Class 7, UN 2977, UF6 Marine shipment (RSB Logistic. DOT 266723) We at RSB Logistic have reviewed the interpretation document (05-0052) that RSB was referred to in our initial request, because it is not an exact comparison, RSB would still request an interpretation of the actual findings to the Tl question below. Any clarification you can offer y,,ould be appreciated, we are eager to solve this discrepancy and avoid further label violations on our Hazmat basic. BRUCE NATSKE Safety & Maintenance Manager RSB LOGISTIC RSB LOGISTIC Inc. · 219 Cardinal Crescent · Saskatoon SK S7L 7K8/Canada Phone.: 306-242-8300 · Fax: 306-242-2311 · safety@rsblogistic.com · www.rsblogistic.com RSB LOGISTIC is a member of Compass Logistics International AG · www.compasslog.com Disclaimer: This message may contain confidential information and is intended solely for the addressee. Any use by third parties is prohibited. From: Bruce Natske Sent: Tuesday, November 07, 2017 2:58 PM To: 'infocntr@dot.gov' Subject: Class 7 Transportation Index (TI) Class 7, UN 2977, UF6 Marine shipment To whom it may concern#

Page 4Recently RSB has run into an issue where we have been issued violations for inconsistent yellow I, II, Ill labels. Sometimes when a flat rack marine shipment comes in from Europe, (each flat rack contains 4 cylinders contained in 4 overpacks, picture attached) each Overpack is labeled and indeed meet the requirements for radioactive II label, no issues there. Under some circumstances the sum of the 4 Over packs Transportation Index contained in one flat rack would meet the requirement for Radioactive Ill label, which is the way it is currently labeled. We have had 2 inspections where RSB received violations for having the 2 different radioactive labels, II on Overpacks and Ill on flat rack. In these cases If we were to label both the Flat rack package and each individual overpack package the same, would be intentionally misrepresenting the Transportation Index on one of the packages. Please clarify so we can make sure we make necessary changes if required to meet the regulations. Sincerely BRUCE NATSKE Safety & Maintenance Manager RSB LOGISTIC RSB LOGISTIC Inc. · 219 Cardinal Crescent · Saskatoon SK S7L ?KB/Canada Phone.: 306-242-8300 · Fax: 306-242-2311 · safety@rsblogistic.com · www.rsblogistic.com RSB LOGISTIC is a member of Compass Logistics International AG · www.compasslog.com Disclaimer: This message may contain confidential information and is intended solely for the addressee. Any use by third parties is prohibited. 2#