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Department of Transportation

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Department of Transportation S. Duann Vanderslice, RPh, BCNP, FAPhA Department of Transportation Purpose Overview of pertinent regulations and describe inspections ... – PowerPoint PPT presentation

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Title: Department of Transportation


1
Department of Transportation
  • S. Duann Vanderslice, RPh, BCNP, FAPhA

2
Department of Transportation
  • Purpose
  • Overview of pertinent regulations and describe
    inspections for compliance in the field.

3
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

4
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.

5
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

6
Department of Transportation
  • The regulations of the DOT are Title 49,
    Transportation, of the Code of Federal
    Regulations

7
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

8
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

9
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

10
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

11
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

12
Department of Transportation
  • Hazmat Employee Training
  • General Awareness
  • Function Specific
  • Safety
  • Security

13
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

14
Department of Transportation
  • The proper shipping name and identification
    number for most shipments made to customers is
    Radioactive Material, Type A Package, UN 2915

15
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

16
Department of Transportation
  • Packaging requirements (cont)
  • Each package must display the appropriate warning
    label on two opposing sides

17
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)

18
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

19
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)

20
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

21
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.

22
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

23
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

24
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

25
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

26
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

27
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

28
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.

29
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

30
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

31
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

32
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

33
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)

34
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

35
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.

36
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.

37
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

38
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

39
Department of Transportation
  • Frequently Cited Violations

40
Department of Transportation
  • Frequently Cited Violations

41
Department of Transportation
  • Frequently Cited Violations

42
Department of Transportation
43
Department of Transportation
44
Department of Transportation
  • Thank you very much for allowing me to share this
    information with you today.
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