REGULATIONS FOR THE SAFE TRANSPORT OF RADIOACTIVE MATERIALS (DS437)
COMMENTS BY REVIEWER
Reviewer: World Nuclear Transport Institute (WNTI)
Country/Organization: World Nuclear Transport Institute (WNTI)
Date: 04/11/10
Comment
No.
Para/Line
No.
1
2
104
Analysis by Pierre Malesys
Page 1 of 20
Proposed new text
Reason
Description of the “rules for reading
the document”, such as the
interpretation of “and”, “or”,
“shall”, “should” and “must”.
Avoid misunderstanding
and wrong interpretation
of regulatory text. See
also T20 resolution of
CA/09/D1.0\1
104. The objective of these Regulations
is to establish requirements that must be
satisfied to ensure safety and to protect
persons, property and the environment
from the effects of radiation in the
transport of radioactive material. This
protection is achieved by requiring:
Approval should be in
italic, because part of
definitions (see title
above para 204).
(a) cContainment of the radioactive
contents;.
(b) cControl of external radiation
levels;.
(c) pPrevention of criticality;. and
Accepted
Accepted, but modified
as follows
Rejected
Reason for
modification/rejection
Rejected
“Approval” is not a
defined word. The
defined terms are
the groups
“multilateral
approval” and
“unilateral
approval”.
“Approval” (as a
single word) should
not be italicized.
Proposed new text:
“Add a new
paragraph 111bis
with the description
of the rules for
reading the
document, such as
the interpretation of
lists (when nothing
is mentioned
between the items
of the list, does it
mean “and” or
“or”?) and the
meaning of “shall”,
“should” and
“must””.
(d) pPrevention of damage caused by
heat.
This was the rule
adopted by CS-19
early this year and
this is the general
practice in the 2009
Edition of the
Regulations. I duly
recognize that this
rule is not
completely
followed currently
and that “approval”
is italicized in a few
instances. If we
really want to make
a comment, it
should be to require
consistency
regarding the
writing of approval
(preferably not
italicized).
These requirements are satisfied firstly
by applying a graded approach to
contents limits for packages and
conveyances and to performance
standards applied to package designs,
depending upon the hazard of the
radioactive contents. Secondly, they are
satisfied by imposing requirements on
the design and operation of packages
and on the maintenance of packagings,
including consideration of the nature of
the radioactive contents. Finally, they
are satisfied by requiring administrative
controls, including, where appropriate,
approval approval by competent
authorities.
3
107(c) bis
4
107 (e)
Transport of a person or animal for
medical treatment, where the person or
animal has been subject to accidental
intake of or contamination from
radioactive material.
The column
“Reasons” should
be filled up. The
main reason is that
this para. 107(c)bis
should be
“parallel” to the
para. 107(c).
Clarification needed for
“natural materials”
considering eenvironmental
samples of contaminated
land. The IAEA safety
glossary suggests that
“naturally occurring
Rejected
- New issue
- To be
complemented
with a proposal
for a new text.
radioactive material
(NORM)” should contain
“no significant amounts of
radionuclides other than
naturally occurring
radionuclides” and that “the
exact definition of
5
217
6
221
“significant amounts”
would be a regulatory
decision.
Conveyance
An aircraft, like a vessel,
may be subdivided into one
217. Conveyance shall mean:
or
more
holds
or
(a) For transport by road or rail: any compartments.
vehicle,.
(b) For transport by water: any vessel,
or any hold, compartment, or
defined deck area of a vessel,. and
(c) For transport by air: any aircraft,
or any hold, or compartment, of an
aircraft.
Exclusive use shall mean the sole
use, by a single consignor, of a
conveyance or of a large freight
container, in respect of which all
initial, intermediate and final
loading and unloading and shipment
is are carried out in accordance with
the directions of the consignor or
consignee, where so required by
these Regulations.
Editorial and no need to
add phrase indicating the
regulations should be
followed. It is now
unclear as to whether or
not exclusive use can be
used even if it is not
required by the
regulations.
Rejected
Proposed new text:
“Exclusive
use
shall mean the sole
use, by a single
consignor, of a
conveyance or of a
large
freight
container,
in
respect of which all
initial, intermediate
and final loading
and unloading and
shipment is are
carried
out
in
accordance
with
the directions of
the consignor or
- New issue
- To be
complemented
with a proposal
for a new text.
consignee, where
so required by
these Regulations
or
by
the
consignor.”
Reason:
Flexibility should
be given to the
consignor to
implement
“exclusive use” if
he decides so.
Internal note for
WNTI members:
It is important to
have the possibility
to perform a
shipment with “all
initial, intermediate
and final loading
and unloading and
shipment carried
out in accordance
with the directions
of the consignor or
consignee” but to
be allowed not to
call it “exclusive
use” if not required
by the Regulations
and, more
importantly, not to
have to implement
all the requirements
subsequent to the
“exclusive use”.
7
223
8
223 +
Annex III
“Enclosed character”
should be deleted to
223. Freight container shall mean
comply with UN and
an article of transport equipment
modal regulations
that is designed to facilitate the
definition, as already
transport of goods, either packaged
proposed by a common
or unpackaged, by one or more
CS meeting between
modes of transport without
intermediate reloading which is of a IAEA and UN on
permanent enclosed character, rigid harmonization. For the
and strong enough for repeated use, same reason, the
definition of small
and must be fitted with devices
facilitating its handling, particularly container should be that
in transfer between conveyances and of UN and modal
regulations. There are no
from one mode of transport to
another. A small freight container is serious reasons to
maintain differences in
that which has either any overall
writing of these
outer dimension less than 1.5 m, or
an internal volume of no less than 1 definitions, since when
used as a package, para
m3 and an internal volume of not
627 contains the
3
more than 3 m . Any other larger
freight container is considered to be “enclosed character”
requirement, and since
a large freight container.
the definition of
exclusive use shipment
does not require the
“enclosed character” for
other transport units
under exclusive use.
Freight container
The list of shipments
requiring exclusive use,
displayed in the Annex III
of the draft TS-R-1, could
be relocated in the main
body of the modal
This is a
new
issue.
We can
try
to
make
this
proposal
as it is
rather
simple
and
straight
forward,
but the
probabi-lity for
its
accep-tance is
rather
low (as
it is a
new
issue)
Reason: “… There
are no serious
reasons to maintain
differences …”
Note that
the
relevant
para. is
221 (and
not 223
This was already
lengthy discussed in
a TM early this
year. It was
recognized that
as stated
In the
second
column).
regulations; this should be
addressed in a
harmonization meeting,
between TS-R-1 and the
UN Model regulations.
Rejected
having this list in an
annex of TS-R-1
did not hamper
having the list in
the main body of
the modal
regulations. It does
not seem needed to
re-open this issue
during an IAEA
meeting.
The issue of the
location of this list
in the modal
regulations has to
be addressed with
the organisations in
charge of the modal
regulations
9
233
Radiation level shall mean the Radiation levels are
corresponding dose rate expressed in sometimes expressed in
millisieverts per hour.
microsievert/hour in the
regulations. It would be
preferable to say
“expressed in dose per
unit of time”.
This is a
new
issue.
We can
try
to
make
this
proposal
as it is
rather
simple
and
straight
forward,
but the
probabi-
We could go further
in the simplification
and to delete
everything about the
unit. The new
definition could be “
Radiation level shall
mean the
corresponding dose
rate expressed in
millisieverts per
hour.”
-lity for
its
accep-tance is
rather
low (as
it is a
new
issue)
10
309
“and who may be affected”:
Does
it
mean
“the
consignor and any previous
carriers,
loaders
and
unloaders who may be
(a) tThe consignor and who may be
affected …”, or does it
affected shall be informed of the
mean “The consignor, when
non-compliance by:
he may be affected …”?.
(i) tThe carrier if the noncompliance is identified
during transport; or
(ii) tThe consignee if the noncompliance is identified at
receipt.
(b) tThe carrier, consignor or
consignee, as appropriate, shall:
(i) tTake immediate steps to
mitigate the consequences
of the non-compliance;.
(ii) iInvestigate
the
noncompliance and its causes,
circumstances
and
consequences;.
(iii) tTake appropriate action to
remedy the causes and
circumstances that led to the
non-compliance and to
prevent a recurrence of
circumstances similar to
those that led to the nonIn the event of non-compliance with
any limit in these Regulations
applicable to radiation level or
contamination:
Rejected
- New issue
- To be
complemented
with a proposal
for a new text
- The regulatory
text seems clear:
“who” means
“all other
parties”. If it
meant “the
consignor, when
he may be
affected”, the
word “and”
should be
deleted between
“the consignor”
and “”who may
be affected”.
(iv)
compliance;. and
cCommunicate
to
the
relevant
competent
authority(ies) on the causes
of the non-compliance and
on corrective or preventive
actions taken or to be
taken;. and
(c)
11
401
12
409(a)
tThe communication of the
non-compliance to the
consignor and the relevant
competent authority(ies),
respectively, shall be made as
soon as practicable and it shall
be immediate whenever an
emergency exposure situation
has developed or is
developing.
TABLE 1
UN 3XXX RADIOACTIVE
MATERIAL, EXCEPTED
PACKAGE - URANIUM
HEXAFLUORIDE, LESS THAN
0.1 KG PER PACKAGE
409. LSA material shall be in one
of three groups:
(a) LSA-I
Either:
(i) Uranium and thorium ores
and concentrates of such
ores, and other ores
containing naturally
“Less than 0.1 kg per
package” should be in
small letters, to shorter
the proper shipping
name. The remaining text
is sufficiently different
from the two other proper
shipping names assigned
to uranium hexafluoride
to avoid confusion.
Referencing exemptions
here, means it should be
done everywhere in the
regulations and not only
for the para. 409 (a) (i). It
is suggested to remove
his unnecessary reference
to para. 107(e). As
written, the criteria for
Accepted
Reason:
“A. Referencing
exemptions in para
409(a)(i) means it
should be done
everywhere in the
regulations and not
only for this para.
409 (a) (i). It is
occurring radionuclides
which do not meet the
applicable provisions of
are intended to be
processed for the use of
these radionuclides. para.
107(e);
(ii) Natural uranium, depleted
uranium, natural thorium
or their compounds or
mixtures, that are
unirradiated and in solid or
liquid form;
(iii) Radioactive material for
which the A2 value is
unlimited,. excluding fissile
material not excepted
under para. 417 Fissile
material with unlimited
A2 value may be included
only if at least one of the
applicable paras 417(a)–
(f) is met; or
(iv) Other radioactive material
in which the activity is
distributed throughout and
the estimated average
specific activity does not
exceed 30 times the values
for activity concentration
specified in paras 402–407,
excluding fissile material
not excepted under para.
417 Fissile material with
unlimited A2 value may
be included only if at
LSA-I does not cover the
new UN number and
proper shipping name
listed in table 1 (LSA-I –
FISSILE). For (ii) and
(iii) it should be written:
“Fissile material may be
included only if at least
one of the applicable
paras 417(a)–(f) or 672(a)
is met”.
suggested to
remove his
unnecessary
reference to para.
107(e).
B. As written, the
criteria for LSA-I
does not cover the
new UN number
and proper
shipping name
listed in table 1
(LSA-I –
FISSILE). For (iii)
and (iv), the
possibility to have
material meeting
the requirement of
para. 672(a) should
be added.
C. 409(a)(iv)
deals, at the
beginning, with
material with a
“specific activity
which does not
exceed 30 times
the value …”.
Then, in the
second part of
409(a)(iv), it is not
relevant to specify
“unlimited A2”.
least one of the
applicable paras 417(a)–
(f) is met.
Proposed new text:
“409. LSA
material shall be in
one of three
groups:
(a) LSA-I
Either:
(i) Uranium and
thorium ores and
concentrates of
such ores, and
other ores
containing
naturally occurring
radionuclides
which do not meet
the applicable
provisions of
para. 107(e);
(ii) Natural
uranium, depleted
uranium, natural
thorium or their
compounds or
mixtures, that are
unirradiated and in
solid or liquid
form;
(iii) Radioactive
material for which
the A2 value is
unlimited ; fissile
material with
unlimited A2
value may be
included only if at
least one of the
applicable paras
417(a)–(f) or
672(a) is met; or
(iv) Other
radioactive
material in which
the activity is
distributed
throughout and the
estimated average
specific activity
does not exceed 30
times the values
for activity
concentration
specified in paras
402–407 ; fissile
material with
unlimited A2
value may be
included only if at
least one of the
applicable paras
417(a)–(f) or
672(a) is met.
13
413
SCO shall be in one of two groups:
(a)
SCO-I: A solid object on
which:
(i)
The non-fixed
contamination on the
accessible surface
averaged over 300 cm2
(or the area of the
surface if less than 300
cm2) does not exceed 4
“Accessible
surface”
needs to be defined.
Rejected
- New issue
- To be
complemented
with a proposal
for a new text
(ii)
14
417
15
418 (c)
Bq/cm2 for beta and
gamma emitters and
low toxicity alpha
emitters, or 0.4 Bq/cm2
for all other alpha
emitters;. and
The fixed
contamination on the
accessible surface
averaged over 300 cm2
(or the area of the
surface if less than 300
cm2) does not exceed 4
× 104 Bq/cm2 for beta
and gamma emitters
and low toxicity alpha
emitters, or 4 × 103
Bq/cm2 for all other
alpha emitters;. and
(f) Other materials that meet the Typo
requirements of para 605bis
subject to multilateral approval.
Only one such material is
allowed per consignment unless
specifically subject to allowed by
multilateral approval.
Contents in a form or physical or
chemical state, or in a spatial
arrangement, different from
those authorized allowed for
the package design as specified
in their certificates of approval
where appropriate.
The allowed specifications are
given either directly in these
Regulations or in certificates of
Given the last sentence
added, there is no need to
keep “as specified in their
certificates of approval
where appropriate” in (c).
More accurate wording.
Do the English
speaking people
support this
“improvement”?
Rejected
- I do not clearly
see the benefit of
our proposal.
- The text in the
draft Regulations
is general, and
avoids missing
one requirement
in the list.
- It is not clear for
me why the
16
419 (c) +
Table 1
17
422(e)
approval where appropriate The
“package design” specifications
are those specified in their
certificates, or those specified in
para. 672(a), 672(b), 672(c) or
672bis when applicable
The proper shipping name and
description should read: “UN No
3XXX RADIOACTIVE
MATERIAL, EXCEPTED
PACKAGE – URANIUM
HEXAFLUORIDE, less than 0.1 kg
per package, non fissile or fissile
excepted”.
(e) They contain less than 0.1 kg
of uranium hexafluoride nonfissile or fissile-excepted.
paragraphs 417(a)
to 417 (f) are not
added to the
paragraphs 672(a),
672(b), 672(c) and
672bis.
The text “less than 0.1 kg Accepted
per package, non fissile
or fissile excepted” needs
to be written in small
letters, in order not to
unnecessary enlarge the
markings to be displayed
on the package and in the
shipping documents.
Nothing is said about
fissile-excepted materials
which are allowed in
excepted packages.
It is proposed to delete
“non-fissile or fissileexcepted” from text in
(e), and to add the
following sentence
applicable to the all para.
422:
“Excepted packages
shall not contain fissile
material, except when
one of the fissile
exceptions provided by
para. 417 applies and the
requirement of para. 634
is met.”
Nothing is said about the
limit of 5 μSv/h at
The new text
should be fully
drafted and
consistent with
paragraph 514.
The subsequent
need for paragraphs
514 and 515 should
be addressed (parts
of these paragraphs
should be deleted).
17
424(c)
18
424bis
19
429
surface, which is a
condition to be met prior
to classify a package as
excepted package. I
propose to add: “To be
classified as excepted
package, the radiation
level at any point of the
external surface of the
package shall not exceed
5 μSv/h” (or add a
reference to para. 515)
For transport by post, the total
This new sentence should Note
activity in each excepted package
be in 424bis.
that the
shall not exceed one tenth of the
previous
relevant limits specified in column 4
comof Table 5. Uranium hexafluoride
-ment
has also
(UN3XXX) is limited to 10g per
the
package for transport by post.
number
17.
UN 2910, RADIOACTIVE
Correction of description
MATERIAL, EXCEPTED
of UN number.
PACKAGE – limited quantity of
material, fissile and non fissile
excepted.
For mixtures of radionuclides whose A clear instruction should
identities and respective activities
be given on which UN
are known, the following condition
number and proper
shall apply to the radioactive
shipping name are to be
contents of a Type A package:
used in that case (choice
between UN2915 and
B(i)
C(j)

1

UN3332 when non-fissile
A 1 (i)
i
j A 2 ( j)
or fissile-excepted,
where
UN3332 or UN3333
B(i) is the activity of radionuclide i
when fissile). It is
as special form radioactive
Accepted, but the
new text for 424(c)
and 424bis should
be drafted.
The text in the draft
Regulations and the
text that we
propose should be
clearly identified.
Rejected
New issue
material;.
A1(i) is the A1 value for radionuclide
i;.
C(j) is the activity of radionuclide j
as other than special form
radioactive material;. and
A2(j) is the A2 value for radionuclide
j.
proposed that: “UN
number shall be
UN2915 when nonfissile or fissileexcepted, UN3332 when
fissile. Proper shipping
name shall be that one
corresponding to the
UN number as stated in
table 1”
This is also a criterion for
classification. See
comment made for para.
422. Shall be referenced
in para. 422.
20
514
If the excepted package contains
fissile material, one of the fissile
exceptions provided by para. 417
shall apply and the requirement of
para. 634 shall be met;.
21
515
The radiation level at any point on
the external surface of an excepted
package shall not exceed 5 μSv/h.
This is also a criterion for
classification. See
comment made for para.
422. Shall be referenced
in para. 422.
22
517
For LSA material and SCO which is
or contains fissile material, that is
not excepted under para. 417, the
applicable requirements of paras
565, 566 and 671 shall be met.
For those materials for
which para. 672 or 672bis
requirements are met,
conditions put under
para. 671 are met. It is
suggested to say “the
applicable requirements
of paras 565, 566 and 671
(or 672 or 672bis) shall
be met.”
What is our
proposal?
This paragraph
should be
considered globally
with our comments
17 and 21.
What is our
proposal?
This paragraph
should be
considered globally
with our comments
17 and 20.
Our text needs to
be improved, so
that the meaning of
the brackets is
clarified.
Proposed new text:
“For LSA material
and SCO which is
or contains fissile
material, that is not
excepted under
para. 417, and for
which the
requirements of
672 and 672bis
are not met, the
applicable
requirements of
paras 565, 566 and
671 shall be met.
23
518(a)
LSA material and SCO in groups LSA-I What does this sentence
and SCO-I may be transported, mean?
unpackaged, under the following
- ores cannot be
conditions:
A proposal should
be fully drafted.
transported
(a) All unpackaged material other
unpackaged, or
than ores containing only
- this para (a) does
naturally occurring radionuclides
shall be transported in such a
not apply to ores
manner that under routine
transported
conditions of transport there will
unpackaged
be no escape of the radioactive
contents from the conveyance nor It is proposed to delete
will there be any loss of this part of the sentence
shielding;.
“other than ores
24
520
25
521
The total activity in a single hold or
compartment of an inland waterway
craft, or in another conveyance, for
carriage of LSA material or SCO in a
Type IP-1, Type IP-2, Type IP-3
package or unpackaged, shall not
exceed the limits shown in Table 7.
The TI for a package, overpack or
freight container, or for unpackaged
LSA-I or SCO-I, shall be the number
derived in accordance with the
following procedure:
containing only naturally
occurring radionuclides”
Is there a valid reason for
limiting activity in inland
waterway craft at lower
values than for other
conveyance?
The TI is determined for
unpackaged material. But
no category is assigned
(see para. 527), no
marking with UN number
Rejected
New issue
Rejected
New issue
and proper shipping name
is required (see para.
528), no labeling is
required (see para. 536),
no placarding is required
(see 541) only the UN
number is required (see
para 542 which is
inconsistent with para.
541).
26
527
Proposals have to be
made to resolve those
inconsistencies of the
regulations.
What about unpackaged
material?
Packages and, overpacks and freight
containers shall be assigned to either
category I-WHITE, II-YELLOW or IIIYELLOW in accordance with the
It is proposed to extend
conditions specified in Table 9 and with this para 527 to
the following requirements:
Rejected
New issue
CATEGORIES OF PACKAGES, AND Should be extended to
OVERPACKS
AND
FREIGHT unpackaged LSA-I and
CONTAINERS d
SCO-I.
Rejected
New issue
“unpackaged LSA-I or
SCO-I”.
27
Table 9
28
Table 9
Footnotes
c and d
C
d
Where the loaded freight container is
neither a package nor an overpack the
limit is 50.
If a package or an overpack requiring
exclusive useshipment is contained in a
freight container, the conveyance
which carries the freight container
shall also be under exclusive use.
For modal regulations, a
freight container cannot
be an overpack and viceversa.
Note “d”means that a
container is no more
considered as a transport
unit (conveyance) as it
has always been the case
by the past and as it is the
This is an
important issue. A
proposal has to be
drafted.
29
528
30
529
case for the other
dangerous goods.
Furthermore, it is
inconsistent with the
definition of exclusive
use given in para. 221. In
practice, this is
inapplicable without
increasing considerably
the cost of shipments.
(only one container per
vehicle, per wagon, per
hold, per inland
waterway vessel …).
Inapplicable when the
overpack contains
packages from different
UN numbers. It is
proposed to replace
“overpack” with
“unpackaged LSA-I or
SCO-I”.
For each package or overpack the
UN number and proper shipping
name shall be determined (see Table
1). In all cases of international
transport of packages requiring
competent authority design or
shipment approval, for which
different approval types apply in the
different countries concerned by the
shipment, the UN number, proper
shipping name, categorization,
labelling and marking shall be in
accordance with the certificate of
the country of origin of design.
Each package shall be legibly and What has to be done for
durably marked on the outside of the unpackaged materials?
packaging with an identification of
either the consignor or consignee, or
both. Each overpack shall be
legibly and durably marked on
the outside of the overpack with
an identification of either the
Rejected
New issue
Rejected
New issue
31
530
32
536
consignor or consignee, or both
unless these markings of all the
packages within the overpack are
clearly visible
Each package and overpack shall be What has to be done for
legibly and durably marked on the unpackaged materials?
outside with the UN marking as
specified in Table 10. Additionally,
each overpack shall be legibly and
durably marked with the word
“OVERPACK” and the UN
marking as specified in Table 10
unless all markings of the
packages are clearly visible.
Each package, overpack and freight What has to be done for
container shall bear the labels which unpackaged materials not
conforming to the applicable models in in large freight
Figs 2, 3 or–4, except as allowed under containers?
the alternative provisions of para. 541 It is proposed that such a
for large freight containers and tanks,
label shall be affixed on
according to the appropriate category.
In addition, each package, overpack the external surface of the
and freight container containing fissile container or the vehicle
material, other than fissile material or of the individual SCOexcepted under the provisions of para. I.
Rejected
New issue
Rejected
New issue
Rejected
New issue
417, shall bear labels which
conforming to the model in Fig. 5. Any
labels which do not relate to the
contents shall be removed or covered.
For radioactive material having other
dangerous properties see para. 506.
33
539
Each label conforming to the model
in Fig. 5 shall be completed with the
CSI as stated in the applicable
certificate of approval for special
arrangement or in the certificate of
approval for the package design
issued by the competent authority or
What has to be done in
case of different CSI
values coming from
different approval
certificates applicable for
the same shipment? The
higher value or the value
34
552bis
35
576
as specified in paras 672 or coming from the country
of origin of the design or
672bis.
the value applicable in
the country of departure?
The consignor shall retain copies of This should be a country
dangerous goods transport
specific requirement as
information as follows:
some countries have less
(a) a copy of the dangerous goods
stringent requirements.
transport document and
additional information and
documentation as specified in
these Regulations shall be
retained for a minimum period
of three months.
(b)
When the documents are
kept electronically or in a computer
system, the consignor shall be able
to reproduce them in a printed form.
A consignment that conforms with the Shall this sentence also
requirements of para. 514, and in which be added in para 577?
Rejected
A proposed text
should be drafted.
the activity of the radioactive contents
does not exceed one tenth of the limits
prescribed in Table 5, may be accepted
for domestic movement by national
postal authorities, subject to such
additional requirements as those
authorities may prescribe. Uranium
hexafluoride (UN3XXX) is limited to
10g per package for transport by
post.
36
615bis
This paragraph should be deleted.
The text is subject to
interpretation.
The box “reason”
should be further
developed. It could
be added that there
is no safety
justification for this
- What is our
proposal?
- It is recognized
that some
countries may
have currently less
stringent
requirements, but
if the draft text is
accepted, these
countries will
have to modify
their regulations.
37
619
38
620
39
626
40
672 (b) +
(c)
Packages
containing
radioactive
material to be transported by air shall
be capable of withstanding, without
leakage loss or dispersal of radioactive
contents from the containment system,
an internal pressure which produces a
pressure differential of not less than
maximum normal operating pressure
plus 95kPa.
An excepted package shall be designed
to meet the requirements specified in
paras 606–616 and, in addition, the
requirements of paras 617–619 if
carried by air.
This should be
harmonized with the
requirements made for
other dangerous goods.
Tanks, other than portable tanks,
may also be used as Type IP-2 or
Type IP-3 for transporting LSA-I
and LSA-II liquids, and gases and
solids as prescribed in Table 6,
provided that:…
This paragraph should be
extended to solids
(powders).
Fissile material meeting one of the
provisions (a) to (d) of para. 417 is
excepted from the requirement to be
transported in packages that comply with
paras 673 –683 as well as the other
requirements of these Regulations that
apply to fissile material. Only one type of
exception is allowed per consignment.
Packages containing fissile material that
meet one of the provisions of subparas
(a)–(c) are excepted from the application
of paras 673–683. The total mass of
subpara (b) and (c)
should include: “and
alternative requirements”
(see para. 624 for IP2 and
IP3, as this should not
address tanks and IP2s
and IP3s).
The main comment for
para. 672 is for cases
where UN packagings,
…and para 634 in case of
fissile material excepted
under para 417.
new para., whilst
there is a risk of
different
implementation of
the requirement by
the competent
authorities.
A proposed text
should be drafted.
A proposed text
should be fully
drafted.
Rejected
- Our proposal
must be fully
drafted
- Para. 626 must de
deleted of the list,
as there are no
tests requirement
in this para.
- “When
applicable”
New issue
beryllium, hydrogenous material
enriched in deuterium, graphite and
other allotropic forms of carbon in an
individual package shall not be greater
than the mass of fissile nuclides in the
package except where their total
concentration does not exceed 1 g in any
103 g of material. Beryllium incorporated
in copper alloys up to 4% in weight of
the alloy does not need to be considered.
(a) Packages containing fissile material
in any form provided that:
(i)
The smallest external
dimension of the package is
not less than 10 cm.
(ii) The CSI of the package is
calculated using the
following formula:
CSI = 50 × 5 × {[mass
of U-235 in package
(g)] / Z +
[mass of
other
fissile
nuclides in
package
(g)] / Y}
Where the values of Z and
Y are taken from Table M.
(iii) The CSI of any package
shall not exceed 10.
(b) Packages containing fissile material
in any form provided that:
(i)
The smallest external
dimension of the package is
not less than 30 cm.
(ii) The package, after being
subjected to the tests
specified in paras 719–724,
shall;
― retain its fissile
material contents.
― preserve the
tanks, IBC or large
freight containers of a
permanent enclosed
character are used as IP-2
or IP-3 following
“alternative requirements
for Type-IP-2 and Type
IP-3 (paras. 624-628). A
large number of
shipments of LSA or
SCO with fissile excepted
material use these
alternatives.
Possibilities. It is
proposed that the
“alternative requirements
allowed for IP-2 and IP3” may also be allowed
for fissile material
complying with 672 (b)
or 672(c). It could read as
follows: “.The package,
after being subjected to
the tests specified in
paras 719–724, (or, when
applicable, to the
alternative test
requirements for Type
IP-2 and Type IP-3
specified in paras. 624
to 628) shall:”
should be more
explicit (see also
my above
comments on
para. 626).
minimum overall
outside dimensions of
the package to at least
30 cm.
― prevent the entry of a
10 cm cube.
(iii) The CSI of the package is
calculated using the
following formula:
CSI = 50 × 2 × {[mass
of U-235 in package
(g)] / Z +
[mass of
other
fissile
nuclides in
package
(g)] / Y}
Where the values of Z and
Y are taken from Table M.
(iv) The CSI of any package
shall not exceed 10.
(c) Packages containing fissile material
in any form provided that:
(i)
The smallest external
dimension of the package is
not less than 10 cm.
(ii) The package, after being
subjected to the tests
specified in paras 719–724,
shall;
― retain its fissile
material contents.
― preserve the minimum
overall outside
dimensions of the
package to at least 10
cm.
― prevent the entry of a
10 cm cube.
(iii) The CSI of the package is
calculated using the
following formula:
CSI = 50 × 2 × {[mass
(iv)
of U-235 in package
(g)]/ Z +
[mass of
other
fissile
nuclides in
package
(g)] / Y}
Where the values of Z and
Y are taken from
Table M.
The maximum mass of
fissile nuclides in any
package shall not exceed 15
g
41
672
footnote a
Correct spelling > “…contains…”.
Typo.
42
Annex III
Title should be: “Shipments
requiring exclusive use”.
43
815-816
Use of excepted package, Type IP1, Type IP-2, Type IP-3 and Type A
package that were not designed to
contain uranium hexafluoride and
that did not require approval of
design by the competent authority
and which meet the requirements of
the 1985 or 1985 (As Amended
1990) Editions of these Regulations
shall be subject to;
(a) The management system in
accordance with the applicable
requirements of para. 306
(b) The activity limits and
classification material
restrictions of in Section IV.
(c) The requirements and controls
for transport in Section V.
Accepted
The title is not
appropriate and should be
changed.
Accepted
It is not clear how the
regulation allow for the
continued use of
packages approved to the
1996 edition of the IAEA
regulations. Suggest
keeping the footnote
found in Section VIII of
the 2009 edition of the
regs, "Although this
publication is identified
as a new edition, there
are no changes that affect
the administrative and
approval requirements in
Section VIII.
Rejected
Our proposal
should be fully
drafted.
I do not see exactly
what is our
comment.
Any packaging modified or
manufactured after 31 December
2003 shall meet this Edition of these
Regulations in full.
Packages prepared for transport shall
meet this Edition of these Regulations
in full, except for packages prepared for
transport prior to 31 December 2003
under the 1985 or 1985 (As Amended
1990) Editions of these Regulations,
which may continue in transport.