Health Physics Questions and Answers - Question 128

Question 128: If a package containing radioactive material is to be shipped, and marking the package as low specific activity (LSA) is the only U.S. Department of Transportation (DOT) warning requirement, is labeling under 10 CFR 20.1904 (a) required?

Answer: No. Although the exemption of 10 CFR 20.1905 (d) applies to U.S. Department of Transportation (DOT)"labeled" containers, not DOT "marked" containers, the Statement of Considerations, in discussing 10 CFR 20.1905 (d) [56 FR 23380, second column], states that "Quantities

and concentrations not requiring DOT labels would not warrant an NRC labeling requirement." See also the answer to Question 36 (10 CFR 20.1906), which indicates that DOT "marked" packages are not DOT "labeled" packages.

(References: 10 CFR 20.1904, 10 CFR 20.1905)