Answer to Question #12438 Submitted to "Ask the Experts"

Is there any labeling or placarding requirement for transport of exempt quantity sealed check sources (e.g., 0.5 µCi ¹³⁷Cs) in a personal vehicle without any other labeling? I know that for shipping, these types of sources must be labeled as UN2910. But what requirements, if any, are needed for local transport by car? is there a Department of Transporation (DOT) or other regulatory reference you can provide?

 

When it comes to shipping questions over the road (in the United States), you correctly note the DOT as the regulating entity. In the DOT world, the first question to ask is "Is it considered radioactive under DOT rules?" The answer and reference for this question is the table of exempt activity concentrations and exempt consignment activity limits within 49 CFR 173.436. In your specific example (¹³⁷Cs), the exempt consignment limit is 0.27 microcuries which means anything below 0.27 microcuries is not considered as radioactive and is not regulated by the DOT. Don't be fooled by the fact that the radioactive materials regulator (Nuclear Regulatory Commission or state) may consider the source to be an exempt quantity," not requiring licensing. That fact is not material to the DOT. To the DOT, this 0.5 microcurie source is considered radioactive and is therefore subject to DOT shipping rules (at least some of them).

If you are shipping material that is considered "radioactive" under the DOT rules, you are required to have DOT shipping training (every three years) and maintain records of that training. I am fairly certain that your source shipment would fall under a "radioactive material, excepted package—limited quantity” classification of shipment. As you say, the requirements for the limited quantity shipment require labeling with the UN2910 label, but there are also other requirements as outlined in 49 CFR 173.421, 173.422, and 173.425. You need to understand these requirements in order to package and ship the material.

Regarding the "personal vehicle," the answer to this question is probably best answered by your personal vehicle insurance. Embedded within your personal auto insurance policy fine print there will likely be a clause that states that your insurance will not cover incidents that involve radioactive materials. Therefore, if the shipment is defined as radioactive material by DOT and you have a crash involving that material, any clean-up charge is out of your pocket. If the accident happened in the course of doing business for your employer, the employer may be responsible for all expenses. That is the biggest reason not to use a personal vehicle to transport radioactive material in my book.

Jeff Brunette, CHP