Transportation of Radioactive
Material by Air
Contractors Transportation
Management Association Conference
Wednesday, July 8, 2015
Point Clear, Alabama
Roy A. Parker, Ph.D.
Radiation Physics Consultant
Air Carriers Transporting
Radioactive Materials

FedEx Express



Domestic – Security Category 1 specified
airports to airports only
Canada – Door to door service
International (except Canada) 023 Airport
to airport only

Possile to arrange door delivery in US and
Canada
Air Carriers Transporting
Radioactive Materials

Fedex Ground



Not ground division of FedEx Express
RAM Excepted Packages and White I only
FedEx Custom Critical

Can handle Security Category 1 shipments
coordinated with FedEx Express flights
Air Carriers Transporting
Radioactive Materials

United Parcel Service

US Domestic Small Package System




RAM Excepted Packages and White I only by contract
No Fissile Material shipment with CSI > 0
US, Canada and Mexico – White I,
Yellow II & Yellow III on UPS Freight, Air Services
by prior arrangement
Outside US & Canada RAM Excepted Packages on
specified routes by prior arrangement.
Air Carriers Transporting
Radioactive Materials

American Airlines



Only US passenger airline that I know
Principally Mallinckrodt out of St. Louis
Foreign Cargo Air Carriers


Lufthansa
Air France
Air Carriers Transporting
Radioactive Materials

Charter Air Carriers – DOT Special
Permit




AirNet (Canada Equivalent Level of Safety)
Ameriflight (Canada Equivalent Level of Safety)
Kalitta Charters
Suburban Air Freight
Ground Carriers Transporting
Radioactive Materials

DOT Special Permit Operators





Associated Couriers
Del-Med
FedEx Express (route specific)
Medical Delivery Services
Tradewind Enterprises
International Transport
Standards and Regulations

49 CFR 171.12 and Part 171 Subpart C
(171.22-171.26)



171.12 Canada TDG Regulations
171.22 Authorization and Conditions
171.23 ICAO, IMDG, TDG and IAEA


Hazardous Substances RQ
Radioactive Material: HRCQ, Fissile,
Type A Quantities – 49 CFR
International Transport
Standards and Regulations

171.23 ICAO, IMDG, TDG and IAEA
Radioactive Materials (contd)





Type A Package – Country of origin adopted
IAEA TS-R-1 (1966)
Type A Package – USA DOT 7A Type A
Medical or Research TI Limit and Certification
Definition of Radioactive Material 49 CFR
Radioactive Material Excepted Packages
International Transport
Standards and Regulations

171.24 ICAO




Highway transport 49 CFR
Placards – Yellow III packages
171.25 IMDG
171.26 IAEA

Into (import), from (export) or through US
M
Y
T
H
IATA Dangerous Goods
Regulations - Misconceptions

IATA 1.5.0.3 Two year training meaningless



49 CFR 172.704(c)(2) Three year training applies
USA DOT 7A Type A (49 CFR 178.350)
Type A Package Documentation must be
maintained for one year after last shipment

January 1, 2017 – Two year retention
(49 CFR 173.415)
Chemical Form
Shipping Paper Entry

For normal form material the chemical
form of the radionuclide is required as a
shipping paper (Shipper’s Declaration
for Dangerous Goods) entry

Sealed sources


Chemical form is not “metal” for example if it is
metal encapsulated
Chemical form is the chemical form of the
radionuclide in the sealed source encapsulation
Don’t
Do
RQ Sequence
Radioactive Materials
and Subrisks



Radioactive Material Excepted Package
is a subrisk to another hazard class
Radioactive material has another hazard
class subrisk – Cargo Aircraft Only
scenario (regulatory driven)
Radioactive material has another hazard
class subrisk – Passenger and CAO
scenario (FedEx Express policy driven)
Radioactive Material Excepted
Package is the Subrisk
UN1993, Flammable liquid, n.o.s. (Ethanol and
toluene mixture), Radioactive Material Excepted
Package –Limited Quantity of Material, 3, II
1 plastic drum (1H2) x 250 mL
305
A130
Radioactive Material Excepted
Package is the Subrisk

Problem: What is the proper shipping
name?



Affects package marking
Proper shipping name is defined as being
listed in the Hazardous Material Table
49 CFR 172.101
Affects package checklist and training
Radioactive Material Excepted
Package is the Subrisk

Does not require Radioactive Material
Excepted Package handling label.
Radioactive Material with
Subrisk – Cargo Aircraft Only
Radioactive Material with
Subrisk – Passenger Aircraft
FedEx Express
IDG Label
FedEx Express
IDG Label

FX-03 Variation: Second Paragraph



FedEx Express will not accept labelled
radioactive material with a subsidiary of 1.4, 3,
4.1, 4.2, 4.3, 5.1, 5.2, 8 or 2.2 with a Cargo
Aircraft Label unless the shipper has been
preapproved.
For approval contact Roy A. Parker, Ph.D.,
Radiation Physics Consultant,
roy@royparker.org or 225-924-1473
You will be sent an IDG information packet.
Overpack Shipping Paper
Format Issue
Overpack Shipping Paper
Format Issue
Overpack Shipping Paper
Format Issue



49 CFR 203(d)(4) and (5) that the
category of label and transport index
must be entered for each package.
Overpack is not specifically addressed.
Some regulators are interpreting the
regulations as requiring label category
and TI for each package plus the
overpack.
Approved Software
FX-18


Requires use of approved software for
completion of Shipper’s Declaration for
Dangerous Goods
DOES NOT APPLY TO:



Radioactive material shipments
Originating in non-US locations
FedEx International, FedEx International
Express Freight (IXF), FedEx International
Premium (IP1), [023 shipments]
Hand Written Shipper’s
Declaration FX-12

Typed or Computer Generated Fields





UN number, proper shipping name, hazard
class or division, subsidiary risk or divisions
packing group
Physical and chemical form or special form,
packaging type
Packing instrctions
Authorization
Emergency telephone number
Hand Written Shipper’s
Declaration FX-12

Permissible hand written radioactive
material fields




Actvity
Category Label – White I, Yellow II,
Yellow III
Transport Index
Package dimensions
Mixtures, Solutions and
Individual Radioactive Sources

For more than one radionuclide indicate

Mixture or solution if applicate in Quantity and
Type of Packing. FX-03



Indvidual Sources


e.g. solid, salt mixture
Gross activity of mixture or solution
List activity of each source
IATA 10.8.3.9.2 Step 7
Activity on label must correspond to declaration
RQ Radioactive Material
Excepted Package

Modified Shippers Declaration
RQ Radioactive Material
Excepted Package



RQ Marking
Not required until July 13, 2015, but do
so anyway to avoid having package
bumped
Dangerous Goods Declaration and
Markings must be consistent.
Passenger and Cargo Aircraft
Cargo Only Aircraft

Not type of aircraft but package classification
Security Category 1
Radionuclide
Curies Radionuclide
Curies
Americium-241
2,000 Plutonium-238
2,000
Californium-252
Curium-244
Cobalt-60
Cesium-337
Gadolinium-153
Iridium-192
500 Promethium-147
1,000,000
1,000 Radium-226
1,000
800 Selenium-75
5,000
3,000 Strontium-90 Y(90)
30,000 Thulium-170
2,000 Yterbium-169
30,000
500,000
8,000
Security Category 1


FedEx Express can transport airport to
airport where there is a customer
service center at the airport ramps.
It is not a violation of regulations for
FedEx Express to transport Category 1
on the ground, but it is a violation for
the shipper to offer an aggregate
Category 1 total to FedEx Express.
Security Category 2
Radionuclide
Curies Radionuclide
Curies
Americium-241
16 Plutonium-238
16
Californium-252
Curium-244
Cobalt-60
Cesium-337
Gadolinium-153
Iridium-192
5.4 Promethium-147
11,000
14 Radium-226
11
8.1 Selenium-75
54
27 Strontium-90 Y(90)
270 Thulium-170
22 Yterbium-169
270
5,400
81
Security Category 2

FedEx Express can pick up and deliver
Category 2 packages, because FedEx
Express has an In Depth Security
Program pursuant to 49 CFR 172.800.
Security Category 3
Radionuclide
Curies Radionuclide
Curies
Americium-241
2 Plutonium-238
2
Californium-252
5 Promethium-147
Curium-244
Cobalt-60
Cesium-337
Gadolinium-153
Iridium-192
1,000
10 Radium-226
1
0.8 Selenium-75
5
3 Strontium-90 Y(90)
0.3 Thulium-170
2 Ytterbium-169
0.3
500
8
Security Categories 3, 4 & 5


There are currently no transportation
security requirements applicable to
Categories 3, 4 and 5
Canada will impose transportation
security requirements on Categories 3,
4 & 5 effective May 31, 2018.
NRC DOT 7A Type A
Fissile Material Packages




49 CFR 173.417(a) recognizes certain fissile material
shipments specified in10 CFR Part 71 Subpart C.
Such shipments are not included in the IATA
Dangerous Goods Regulations and FedEx Express
training does not cover such shipments.
A blanket approval letter for domestic shipments has
been issued for these shipments by FedEx Express.
This shipment approval letter must be completed and
accompany all such shipments.
Recent Fissile Excepted
Regulation Changes



Recent changes in IATA no longer specify that “Fissile
Excepted” be entered in the Packing Instruction
column, but specify that the applicable IATA
paragraph be referenced.
Reference to a trade organization tariff is not an
acceptable regulatory practice and will cause
confusion.
I recommend continued use of “Fissile Excepted”
until this is resolved.
Hazmat Training
49 CFR 172 Subpart H

Hazmat Employee




Loads, unload, handles
Tests, reconditions, repairs, modifies,
marks, packaging
Prepares hazardous material for
transportation
Operates a vehicle transporting hazardous
materials
Training


IATA 1.5.0.3 Recurrent training must be
provided with 24 months of previous
training – MYTH
49 CFR 172.704(c)(2) A hazmat
employee must receive training … at
least once every three years. FACT
Hazmat Training
Certification and Instructor




Employer certifies the training, not the course
instructor
No prerequisite qualifications for the course
instructor
Self training permitted
Anyone may provide HazMat training provided
it is complete, accurate and applicable to the
HazMat operations being performed
Hazmat Training
49 CFR 172 Subpart H


Training must be complete within 90
days after assignment to hazmat duties
Subject Areas





General awareness and familiarization
Function specific
Safety training
Security Awareness Training
In-Depth Security Training
Hazmat Training
In-Depth Security Training


Effective October 1, 2010
Old:



Yellow III
Highway Route Control Quantity
New:


IAEA Category II per package
Highway Route Control Quantity
Hazmat Training
In-Depth Security Training

Written Security Plan





Personnel Security
Unauthorized Access
En-route Security
New Site Specific
New Annual Site Specific Assessment
Hazmat Training
Record Keeping




Record keeping is the key
Maintain during employment and 90
days thereafter
Hazmat employees name
Most recent Hazmat training completion
date
Hazmat Training
Record Keeping



Description, copy or location of hazmat
training materials
Name and address of person providing
training
Certification hazmat employee has been
trained and tested
Don’t
Safety
Emergency Response Information




Available away from package
Not required to attached emergency
instructions
MSDS sheet not applicable to
radioactive materials
Emergency Response Guidebook (2012)
Safety
Emergency Response Guidebook



Available for download at hazmat.dot.gov
Facility Operators: Must be immediately
available where hazardous material is
received, stored or handled during
transportation.
Carrier: Maintain on board with shipping
paper information, notice to pilot in
command, or dangerous goods manifest
Twenty-Four Hour Telephone
Emergency Number




Monitored at all times hazardous
material is in transportation, including
storage incidental to transportation
Pagers may not be used
Answering services may be used if
forwarded immediately (risky)
Answering services may be given
appropriate information (risky)
Twenty-Four Hour Telephone
Emergency Number

Telephone number of person who is
either knowledgeable of the hazardous
material being shipped and has
comprehensive emergency response
and incident mitigation information for
that material or who has immediate
access to a person who posses such
knowledge and information
Twenty-Four Hour Telephone
Emergency Number


Shipper’s name and Emergency Telephone
Number of Shipper or Emergency Response
Information (ERI) provider contracted by
shipper.
If shipper does not contract with ERI provider
then name or contract number of third party
who authorizes shipper to use the ERI
provider under their contract.
Type A Package

To my current best knowledge

No Type A packages are available for
purchase off the shelf that fully meet the
Type A package documentation
requirements



Except the Biodex packaging system for F-18
Except the Croft Type A Packages
No package testing company can fully
provide complete Type A package
documentation.
Type A Package


Many shippers think that only the tests
are required for Type A package
documentation.
Criteria


no loss or dispersal of radioactive contents
no loss of shielding integrity which would result
in more than a 20% increase in the radiation
level at any external surface of the package.
Type A Package

Type A package documentation must
address all the points in

173.410 General Design Requirements

173.412 Additional Design Requirements
for Type A Packages

173.465 Type A Packaging Tests

173.466 Additional Tests for Type A
Packages Designed for Liquids and Gases.
Thank You
Roy A. Parker, Ph.D.
Radiation Physicist
5061 Abelia Drive
Baton Rouge, Louisiana 70808
Tel: 225-924-1473
Fax: 225-924-4269
Email: roy@royparker.org