Health Physics Questions and Answers - Question 127

Question 127: 10 CFR 20.1904 (a), Labeling containers, indicates in a parenthetical statement that "the radionuclides (s) present" may now be intended to be a part of the information required to be included on labels. In reply to comments on this rule, the preamble (56 FR 23380, first column) provides a special interpretation for nuclear power plant licensees as to acceptable methods for compliance for labeling fission and activation product containers. Taken together, the rule and preamble can be understood to mean that nuclear power plant licensees are required by the revised Part 20 to include the words "activation products" and/or "mixed fission products" on all containers in which greater than an Appendix C quantity is present - a considerable undertaking which would not contribute appreciably to radiation protection. Do the words "such as" in the parenthetical statement mean that this interpretation is incorrect?

Answer: Yes. This interpretation of the rule and preamble is incorrect. The parenthetical statement provides examples of the types of information that may be included on the label; it is not a requirement to include all of the information in the parenthetical statement. However, 10 CFR 20.1904 does require the label to include sufficient information to permit individuals handling or using the containers, or working in the vicinity of the containers, to take precautions to avoid or minimize exposures. Simply having only "Caution, Radioactive Material" or "Danger, Radioactive Material" on the label is not sufficient.

(Reference: 10 CFR 20.1904)