Department of Transportation

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Department of Transportation

• S. Duann Vanderslice, RPh, BCNP, FAPhA

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Department of Transportation

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

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Department of Transportation

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

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Department of Transportation

• Agencies controlling transportation
• Nuclear Regulatory Commission (USNRC) defers to
  the DOT regulations regarding shipment of
  radioactive materials.
• USNRC also assists and advises the DOT in
  establishing safety standards.

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Department of Transportation

• The Regulations of the NRC are Title 10, Energy,
  of the Code of Federal Regulations
• NRC regulations pertaining to transportation are
  found in Part 71

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Department of Transportation

• The regulations of the DOT are Title 49,
  Transportation, of the Code of Federal
  Regulations

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Department of Transportation

• US Government Regulations
• Required to have access to these Titles, as well
  as others that affect your business, at each
  facility
• As a worker, it is your right and responsibility
  to review these Titles
• The Radiation Safety Officer (RSO) of your
  facility can show you where you can access these
  regulations

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Department of Transportation

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

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Department of Transportation

• Class 1 - Explosives
• Class 2 - Gases (Flammable gas)
• Class 3 - Flammable liquid
• Class 4 - Flammable solid
• Class 5 - Oxidizers and Organic Peroxides
• Class 6 - Toxics and Infectious Substances
• Class 7 - Radioactive Material
• Class 8 - Corrosive Materials
• Class 9 - Miscellaneous Dangerous Goods

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Department of Transportation

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

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Department of Transportation

• A HazMat employee is anyone that is involved in
  the transportation of hazardous materials,
  including
• Preparing, repairing, or testing packages used to
  transport them
• Moving them by motor vehicle
• Loading or unloading them
• Responsibility for the safety aspects of the
  transportation

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Department of Transportation

• Hazmat Employee Training
• General Awareness
• Function Specific
• Safety
• Security

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Department of Transportation

• Identification Requirements
• The DOT regulations require specific information
  to appear on the shipping papers and packaging
• This information is intended to enable employees
  to recognize and identify hazardous materials and
  to assess the relative risk in handling specific
  packages

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Department of Transportation

• The proper shipping name and identification
  number for most shipments made to customers is
  Radioactive Material, Type A Package, UN 2915

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Department of Transportation

• Other packaging requirements
• Type A Packages for RAM with security seal 49 CFR
  273.412(b)
• Orientation Arrows on opposite sides (liquids) 49
  CFR 172.312
• Name and address of shipper
• Name and address of recipient
• If the package contains a reportable quantity of
  material, the letters RQ must appear either
  before or after the proper shipping name

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Department of Transportation

• Packaging requirements (cont)
• Each package must display the appropriate warning
  label on two opposing sides

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Department of Transportation

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

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Department of Transportation

• Contents
• The name of the radionuclide(s) as taken from the
  listing in 173.435. Only authorized symbols
  (abbreviations) allowed
• Mixtures of radionuclides must appear in order of
  decreasing radiotoxicity as space permits

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Department of Transportation

• Transport Index
• The transport index (if required) must be entered
  in the provided box
• TI is a dimensionless number
• Any number to the right and it is rounded up to
  the next decimal place (1.04 would be 1.1)

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Department of Transportation

• Type A Packaging
• Must be designed to comply with 49 CFR 173.23,
  173.24a, 173.410 and 173.412
• Must be adequate to prevent the loss or dispersal
  of its radioactive contents when subjected to the
  normal conditions of transport
• Undergoes performance tests to simulate the
  normal rigors and environmental conditions

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Department of Transportation

• Type A Packaging
• Shipper must have documentation that the package
  passed the required performance tests.
• Any alteration of the package or packaging
  materials invalidates the performance tests.
• Packages should be marked with certificate number
  and with Manufacturer and city/state of
  manufacturer.

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Department of Transportation

• Shipping Paper Requirements
• Proper shipping name
• Hazard Class 7
• Identification number (UN)
• Letters RQ (when applicable)
• Radionuclide(s) contained in the package
• Physical and Chemical Form of the materials
• Activity in SI units

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Department of Transportation

• Shipping Paper Requirements
• Category of the radioactive warning label (WI,
  etc.)
• Transport Index (if required)
• Shippers Certification
• Time of Delivery
• Shippers name, address and phone number
• 24 hour contact information

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Department of Transportation

• Contamination Control
• The DOT regulations prescribe limits for control
  of removable (non-fixed) contamination 49 CFR
  173.443
• Limits are 2,200 dpm/100 cm2
• In the interest of ALARA many may set their
  internal limit below this amount

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Department of Transportation

• Carriers
• May not knowingly accept for transport packages
  of RAM which have not been properly described and
  certified by the shipper pursuant to 49 CFR
  172.204
• Place packages only in trunk or cargo area
• Secure packages from movement (block and brace)
• Total transport index (TI) cannot exceed 50

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Department of Transportation

• Safety
• Carrier must assure that the DOT and shipper are
  notified in the event of fire, breakage, spillage
  or suspected radioactive contamination involving
  a shipment
• Carrier must assure that vehicles, areas, or
  equipment in which RAM may have spilled are not
  placed in service again until they have been
  surveyed and decontaminated

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Department of Transportation

• Security
• Vehicles containing RAM must be locked at all
  times
• Deliveries must be left in a secured location not
  accessible to the general public

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Department of Transportation

• Security
• Keys and codes to restricted areas (for
  recipients and the pharmacy) should be kept as
  confidential as possible.
• When personnel change, keys/codes should too.

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Department of Transportation

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

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Department of Transportation

• Limited Quantity shipments are exempted from the
  specification packaging, labeling, and the
  shipping paper and certification requirements of
  radioactive materials shipments
• There are certain requirements a Limited Quantity
  shipment must meet in order to qualify for the
  above mentioned exemption

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Department of Transportation

• The package meets the general design requirements
  of 49 CFR 173.410
• The radiation level at any point on the surface
  of the package does not exceed 0.5 mR/hour
• Removable contamination on the external surface
  does not exceed 22 dpm/cm2 or 2200 dpm/100 cm2

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Department of Transportation

• The activity of the package does not exceed the
  prescribed amounts for Limited Quantities
  Shipments
• Normal form Limited Quantity activity limits
• Solids and gases 1/1,000 of A2 value
• Liquids 1/10,000 of the A2 value

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Department of Transportation

• The package must be certified as being acceptable
  for transportation by having a notice enclosed in
  or on the package. It must have the name of the
  consignor or the consignee and the following
  statement
• This package conforms to the conditions and
  limitations specified in 49 CFR 173.421 for
  radioactive material, excepted package-limited
  quantity of material,UN 2910
• 49 CFR 173.422(a)

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Department of Transportation

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

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Department of Transportation

• Inspections
• They can occur at any time.
• Always be prepared.
• Keep organized records.
• First and foremost, remain calm with the
  inspector.
• Only answer the question that is asked.
• Stay with the inspector and never hand them
  stacks of paperwork.

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Department of Transportation

• Inspections
• It is important for all the people who are HazMat
  employees, to be able to answer questions posed
  by the DOT
• Questions should be regulations-based
• You do have the right to appeal findings and
  fines assessed.

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Department of Transportation

• Most Likely times to be inspected
• Post accidents
• Post reporting to the NRC/agreement state
• On the anniversary of your last inspection
• Post Hospital inspection
• Post FedEx inspection

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Department of Transportation

• Common items to be inspected
• Training records
• Bills of Lading
• Package Certificates
• Emergency procedures
• Conditions of packages
• Vehicles
• Knowledge of the people

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Department of Transportation

• Frequently Cited Violations

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Department of Transportation

• Frequently Cited Violations

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Department of Transportation

• Frequently Cited Violations

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Department of Transportation
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Department of Transportation
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Department of Transportation

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