Health Physics Questions and Answers - Question 53

Question 53:

(a) When a package is properly labeled for transport, shipping papers are still in effect, and a transporter has accepted responsibility for control of the package, do posting and labeling requirements remain in effect while the package is on licensee property outside of the radiologically controlled area?

(b) Does the shipment have to be posted in the protected area?

(c) Does the shipment have to be posted within the owner-controlled area?

(d) Once the transporter has taken control of a package and shipping papers are in effect, is the shipment exempt from posting?

Answer: The answer to all four questions is that the posting requirements remain in effect until the transporter has actually taken possession of the package and is starting to transport it. Following are additional responses to three of the four specific questions:

(a) 10 CFR 20.1905 (d) exempts this package from the labeling requirements of 10 CFR 20.1904 (a).

(b) Whether or not the package is in a "protected area," as defined in 10 CFR 73.2, is not relevant to any requirements in 10 CFR Part 20.

(c) Whether or not the package is in an "owner-controlled area" (or "controlled area" as defined in 10 CFR Part 20) is not relevant to the posting requirements of 10 CFR 20.1902 (e).

(References: 10 CFR 20.1902 (e), 10 CFR 20.1903, 10 CFR 20.1904 (a), 10 CFR 20.1905 (d))