Department of Transportation

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

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

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

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.

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

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

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

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

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

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

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

Department of Transportation • Hazmat Employee Training • General Awareness • Function Specific • Safety • Security

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

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

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

Department of Transportation • Packaging requirements (con’t): • Each package must display the appropriate warning label on two opposing sides

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)

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

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)

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

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.

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

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

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

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

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

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

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.

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

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

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/100cm2

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

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)

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”

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.

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.

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

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

Department of Transportation • Frequently Cited Violations

Department of Transportation

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

Department of Transportation