Department of Transportation S. Duann Vanderslice, RPh, BCNP, FAPhA.

Department of Department of TransportationTransportation

S. Duann Vanderslice, RPh, BCNP, FAPhAS. Duann Vanderslice, RPh, BCNP, FAPhA


PurposePurpose

Overview of pertinent regulations and Overview of pertinent regulations and describe inspections for compliance in describe inspections for compliance in the field.the field.


Agencies controlling transportationAgencies controlling transportation

Department of Transportation Department of Transportation (DOT) (DOT) under the DOT act of 1966 has under the DOT act of 1966 has regulatory responsibility for safety in the regulatory responsibility for safety in the transportation of all hazardous transportation of all hazardous materials, including radioactive materials, including radioactive materialsmaterials


Agencies controlling transportationAgencies controlling transportation

Nuclear Regulatory Commission Nuclear Regulatory Commission (USNRC) (USNRC) defers to the DOT regulations defers to the DOT regulations regarding shipment of radioactive regarding shipment of radioactive materials.materials.

USNRC also assists and advises the DOT USNRC also assists and advises the DOT in establishing safety standards.in establishing safety standards.


The Regulations of The Regulations of the NRC are the NRC are Title Title 1010, Energy, of the , Energy, of the Code of Federal Code of Federal RegulationsRegulations

NRC regulations NRC regulations pertaining to pertaining to transportation are transportation are found in found in Part 71Part 71


The regulations of The regulations of the DOT are the DOT are Title Title 4949, Transportation, , Transportation, of the Code of of the Code of Federal Federal RegulationsRegulations


US Government RegulationsUS Government Regulations Required to have access to these Titles, Required to have access to these Titles,

as well as others that affect your as well as others that affect your business, at each facilitybusiness, at each facility

As a worker, it is your right and As a worker, it is your right and responsibility to review these Titlesresponsibility to review these Titles

The Radiation Safety Officer (RSO) of The Radiation Safety Officer (RSO) of your facility can show you where you your facility can show you where you can access these regulationscan access these regulations


Hazard ClassHazard Class - the category of - the category of hazard assigned to a hazardous hazard assigned to a hazardous material as defined in 49 CFR 173 material as defined in 49 CFR 173 and the provisions of the table found and the provisions of the table found in 49 CFR172.101 in 49 CFR172.101


Class 1 - ExplosivesClass 1 - Explosives Class 2 - Gases Class 2 - Gases

(Flammable gas)(Flammable gas) Class 3 - Flammable liquidClass 3 - Flammable liquid Class 4 - Flammable solidClass 4 - Flammable solid Class 5 - Oxidizers and Class 5 - Oxidizers and

Organic PeroxidesOrganic Peroxides Class 6 - Toxics and Class 6 - Toxics and

Infectious SubstancesInfectious Substances Class 7Class 7 - - Radioactive Radioactive

MaterialMaterial Class 8 - Corrosive Class 8 - Corrosive

MaterialsMaterials Class 9 - Miscellaneous Class 9 - Miscellaneous

Dangerous GoodsDangerous Goods


Hazardous Materials ShipmentsHazardous Materials Shipments

For our purposes, a HazMat Shipment is For our purposes, a HazMat Shipment is any package containing radioactive any package containing radioactive material that is transported from one material that is transported from one place to anotherplace to another


A HazMat employee is anyone that is A HazMat employee is anyone that is involved in the transportation of hazardous involved in the transportation of hazardous materials, including:materials, including:

Preparing, repairing, or testing packages used to Preparing, repairing, or testing packages used to transport themtransport them

Moving them by motor vehicleMoving them by motor vehicle Loading or unloading themLoading or unloading them Responsibility for the safety aspects of the Responsibility for the safety aspects of the

transportationtransportation


Hazmat Employee TrainingHazmat Employee Training

General AwarenessGeneral Awareness Function SpecificFunction Specific SafetySafety SecuritySecurity


Identification RequirementsIdentification Requirements

The DOT regulations require specific The DOT regulations require specific information to appear on the shipping information to appear on the shipping papers and packagingpapers and packaging

This information is intended to enable This information is intended to enable employees to recognize and identify employees to recognize and identify hazardous materials and to assess the hazardous materials and to assess the relative riskrelative risk in handling specific packages in handling specific packages


The proper shipping The proper shipping name and name and identification identification number for most number for most shipments made to shipments made to customers is customers is Radioactive Radioactive Material, Type A Material, Type A Package, UN Package, UN 29152915


Other packaging requirements:Other packaging requirements: Type A Packages for RAM with security seal Type A Packages for RAM with security seal

49 CFR 273.412(b)49 CFR 273.412(b) Orientation Arrows on opposite sides Orientation Arrows on opposite sides

(liquids) (liquids) 49 CFR 172.31249 CFR 172.312

Name and address of shipperName and address of shipper Name and address of recipientName and address of recipient If the package contains a reportable quantity If the package contains a reportable quantity

of material, the letters RQ must appear of material, the letters RQ must appear either before or after the proper shipping either before or after the proper shipping namename


Packaging requirements (con’t):Packaging requirements (con’t):

Each package must display the Each package must display the appropriate warning label on two appropriate warning label on two opposing sidesopposing sides


Warning Labels:Warning Labels:

The following applicable items of The following applicable items of information must be entered in the blank information must be entered in the blank spaces on the Radioactive label by legible spaces on the Radioactive label by legible printing (manual or mechanical) using a printing (manual or mechanical) using a durable weather resistant means of durable weather resistant means of marking marking (49 CFR 173.403)(49 CFR 173.403)


ContentsContents The name of the The name of the

radionuclide(s) as taken radionuclide(s) as taken from the listing in from the listing in 173.435. Only 173.435. Only authorized symbols authorized symbols (abbreviations) allowed(abbreviations) allowed

Mixtures of radionuclides Mixtures of radionuclides must appear in order of must appear in order of decreasing radiotoxicity decreasing radiotoxicity as space permitsas space permits


Transport IndexTransport Index The transport index (if The transport index (if

required) must be required) must be entered in the provided entered in the provided boxbox

TI is a dimensionless TI is a dimensionless numbernumber

Any number to the right Any number to the right and it is rounded up to and it is rounded up to the next decimal place the next decimal place (1.04 would be 1.1)(1.04 would be 1.1)


Type A PackagingType A Packaging Must be designed to comply with 49 CFR Must be designed to comply with 49 CFR

173.23, 173.24a, 173.410 and 173.412173.23, 173.24a, 173.410 and 173.412 Must be adequate to prevent the loss or Must be adequate to prevent the loss or

dispersal of its radioactive contents when dispersal of its radioactive contents when subjected to the normal conditions of subjected to the normal conditions of transporttransport

Undergoes performance tests to simulate the Undergoes performance tests to simulate the normal rigors and environmental conditionsnormal rigors and environmental conditions


Type A PackagingType A Packaging Shipper must have documentation that the Shipper must have documentation that the

package passed the required performance package passed the required performance tests.tests.

Any alteration of the package or packaging Any alteration of the package or packaging materials invalidates the performance tests.materials invalidates the performance tests.

Packages should be marked with certificate Packages should be marked with certificate number and with Manufacturer and number and with Manufacturer and city/state of manufacturer.city/state of manufacturer.


Shipping Paper Requirements:Shipping Paper Requirements:

Proper shipping nameProper shipping name Hazard Class 7Hazard Class 7 Identification number (UN)Identification number (UN) Letters RQ (when applicable)Letters RQ (when applicable) Radionuclide(s) contained in the packageRadionuclide(s) contained in the package Physical and Chemical Form of the materialsPhysical and Chemical Form of the materials Activity in SI unitsActivity in SI units


Shipping Paper Requirements:Shipping Paper Requirements:

Category of the radioactive warning label Category of the radioactive warning label (WI, etc.)(WI, etc.)

Transport Index (if required)Transport Index (if required) Shipper’s CertificationShipper’s Certification Time of DeliveryTime of Delivery Shipper’s name, address and phone numberShipper’s name, address and phone number 24 hour contact information24 hour contact information


Contamination ControlContamination Control

The DOT regulations prescribe limits for The DOT regulations prescribe limits for control of removable (non-fixed) control of removable (non-fixed) contaminationcontamination 49 CFR 173.44349 CFR 173.443

Limits are 2,200 dpm/100 cmLimits are 2,200 dpm/100 cm22

In the interest of ALARA many may set In the interest of ALARA many may set their internal limit below this amounttheir internal limit below this amount


Carriers:Carriers: May not knowingly accept for transport May not knowingly accept for transport

packages of RAM which have not been packages of RAM which have not been properly described and certified by the properly described and certified by the shipper pursuant to 49 CFR 172.204shipper pursuant to 49 CFR 172.204

Place packages only in trunk or cargo areaPlace packages only in trunk or cargo area Secure packages from movement (block Secure packages from movement (block

and brace) and brace) Total Total transport index (TI) transport index (TI) cannot exceed cannot exceed

5050


Safety Safety Carrier must assure that the DOT and Carrier must assure that the DOT and

shipper are notified in the event of fire, shipper are notified in the event of fire, breakage, spillage or suspected radioactive breakage, spillage or suspected radioactive contamination involving a shipmentcontamination involving a shipment

Carrier must assure that vehicles, areas, or Carrier must assure that vehicles, areas, or equipment in which RAM may have spilled equipment in which RAM may have spilled are not placed in service again until they are not placed in service again until they have been surveyed and decontaminatedhave been surveyed and decontaminated


SecuritySecurity

Vehicles containing RAM must be Vehicles containing RAM must be locked at all times locked at all times

Deliveries must be left in a secured Deliveries must be left in a secured location not accessible to the general location not accessible to the general publicpublic


SecuritySecurity

Keys and codes to restricted areas (for Keys and codes to restricted areas (for recipients and the pharmacy) should recipients and the pharmacy) should be kept as confidential as possible.be kept as confidential as possible.

When personnel change, keys/codes When personnel change, keys/codes should too.should too.


The proper shipping The proper shipping name and name and identification numberidentification number for the majority of for the majority of packages received packages received from customers is from customers is Radioactive Radioactive Material, excepted Material, excepted package – limited package – limited quantity of quantity of material, UN2910material, UN2910


Limited Quantity Limited Quantity shipments are shipments are exempted from the specification exempted from the specification packaging, labeling, and the shipping packaging, labeling, and the shipping paper and certification requirements of paper and certification requirements of radioactive materials shipmentsradioactive materials shipments

There are certain requirements a There are certain requirements a Limited QuantityLimited Quantity shipment must meet shipment must meet in order to qualify for the above in order to qualify for the above mentioned exemptionmentioned exemption


The package meets the general design The package meets the general design requirements of 49 CFR 173.410requirements of 49 CFR 173.410

The radiation level at any point on the The radiation level at any point on the surface of the package does not surface of the package does not exceed 0.5 mR/hourexceed 0.5 mR/hour

Removable contamination on the Removable contamination on the external surface does not exceed external surface does not exceed 22 dpm/cm22 dpm/cm2 2 or 2200 dpm/100or 2200 dpm/100 cmcm22


The activity of the package does not The activity of the package does not exceed the prescribed amounts for exceed the prescribed amounts for Limited Quantities ShipmentsLimited Quantities Shipments

Normal form Normal form Limited QuantityLimited Quantity activity limits:activity limits: Solids and gases 1/1,000 of ASolids and gases 1/1,000 of A22 value value Liquids 1/10,000 of the ALiquids 1/10,000 of the A22 value value


The package must be certified as being The package must be certified as being acceptable for transportation by having a acceptable for transportation by having a notice enclosed in or on the package. It notice enclosed in or on the package. It must have the name of the consignor or the must have the name of the consignor or the consignee and the following statement: consignee and the following statement:

““This package conforms to the conditions This package conforms to the conditions and limitations specified in 49 CFR 173.421 and limitations specified in 49 CFR 173.421 for radioactive material, excepted package-for radioactive material, excepted package-limited quantity of material,UN 2910” limited quantity of material,UN 2910”

49 CFR 173.422(a)49 CFR 173.422(a)


The outside of the inner packaging The outside of the inner packaging or, if there is no inner packaging, the or, if there is no inner packaging, the outside of the package itself bears outside of the package itself bears the marking the marking “Radioactive”“Radioactive”


InspectionsInspections They can occur at any time.They can occur at any time. Always be prepared. Always be prepared. Keep organized records.Keep organized records. First and foremost, remain calm with the First and foremost, remain calm with the

inspector.inspector. Only answer the question that is asked.Only answer the question that is asked. Stay with the inspector and never hand Stay with the inspector and never hand

them stacks of paperwork.them stacks of paperwork.


InspectionsInspections It is important for all the people who are It is important for all the people who are

HazMat employees, to be able to answer HazMat employees, to be able to answer questions posed by the DOTquestions posed by the DOT

Questions should be regulations-basedQuestions should be regulations-based You do have the right to appeal findings You do have the right to appeal findings

and fines assessed.and fines assessed.


Most Likely times to be inspectedMost Likely times to be inspected

Post accidentsPost accidents Post reporting to the NRC/agreement statePost reporting to the NRC/agreement state On the anniversary of your last inspectionOn the anniversary of your last inspection Post Hospital inspectionPost Hospital inspection Post FedEx inspectionPost FedEx inspection


Common items to be inspectedCommon items to be inspected

Training recordsTraining records Bills of LadingBills of Lading Package CertificatesPackage Certificates Emergency proceduresEmergency procedures Conditions of packagesConditions of packages VehiclesVehicles Knowledge of the peopleKnowledge of the people


Frequently Cited Frequently Cited ViolationsViolations

Violation Violation Section or CiteSection or Cite Baseline Baseline AssessmentAssessment

Failure to Failure to provide initial provide initial training w/n 90 training w/n 90 days of days of employmentemployment

172.702172.702 >10 $700 each>10 $700 each

<10 $400 each<10 $400 each

Failure to Failure to provide provide recurrent recurrent training every training every 3yrs3yrs

172.702172.702 >10 $400 each>10 $400 each

<10 $275 each<10 $275 each



Violation Violation Section or Section or CiteCite

Baseline Baseline AssessmentAssessment

Failure to provide a Failure to provide a shipping papershipping paper

172.201172.201 $3000 to $3000 to $6000$6000

Failure to retain Failure to retain shipping papers (375 shipping papers (375 days)days)

172.201(e)172.201(e) $1000$1000

Failure to include a Failure to include a hazard classhazard class

172.202172.202 $1000 to $1000 to $2000$2000



Violation Violation Section or CiteSection or Cite Baseline Baseline AssessmentAssessment

Failure to Failure to include RQinclude RQ

172.203 (c) (2)172.203 (c) (2) $500$500

Failure to sign Failure to sign the shipper’s the shipper’s certificationcertification

172.204172.204 $800$800

No emergency No emergency response response numbernumber

172.604172.604 $2600$2600



Baseline Baseline AssessmentAssessment

Failure to mark Failure to mark package in letters package in letters 13mm high “Type A”13mm high “Type A”

172.310 (b)172.310 (b) $800$800

Placing a label on Class Placing a label on Class 7 that underestimates 7 that underestimates the categorythe category

172.403172.403 $5000$5000

No tamper resistant No tamper resistant devicedevice

173.412(a)173.412(a) $2000$2000



Baseline Baseline AssessmeAssessmentnt

Offering Limited Quantity Offering Limited Quantity w/o meeting the w/o meeting the requirementsrequirements

173.421(a)173.421(a) $4000$4000

Offering a package that Offering a package that exceeds limits for surface exceeds limits for surface radiation or TIradiation or TI

173.441173.441 $10000 and $10000 and upup

Offering a package w/o Offering a package w/o determining level of determining level of removable contamination removable contamination or exceeds the levelor exceeds the level

173.443173.443 $5000 and $5000 and upup


Thank you very much for allowing me to Thank you very much for allowing me to share this information with you today.share this information with you today.

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Department of Transportation S. Duann Vanderslice, RPh, BCNP, FAPhA.

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