DOE Guidance for Preparing DOT CAC Applications for Compliance with IAEA Regulations
This guidance applies only to DOE elements or persons working under contract to DOE elements
DOE elements means programs, operations offices, field/site offices, and other organizational units of the Department of Energy, excluding those of the National Nuclear Security Administration. The list of DOE elements is here. 
(link to DOE Directives website).
This guidance webpage will refer to DOE elements or persons working under to contract (i.e., contractors) to DOE elements as the "Applicant to DOE", unless otherwise specified. For DOE application submittals to DOT, the DOE Packaging Certification Program (PCP) Manager or DOE Headquarters Certifying Official (HCO) is the "Applicant to DOT."
DOE Requirements
DOE Order 460.1D, Hazardous Materials Packaging and Transportation Safety (opens pdf) requires Applicants to DOE to file a request to the HCO for a new US Dept. of Transportation (DOT) Competent Authority Certificate (CAC) to authorize use of a Type B or fissile package design for export/import, or file a request for revision or extension of a current DOT CAC. (see also 49 CFR 173.472 Requirements for exporting DOT Specification Type B and fissile packages.)
DOE Guidance for compliance with IAEA Regulations
DOT issues CACs to DOE certificate holders based on DOT endorsement of a DOE or NRC Certificate of Compliance (CoC) for Type B of fissile package design certified to the US regulations (10 CFR Part 71), and compliance with the International Atomic Energy Agency (IAEA) regulations for the Safe Transport of Radioactive Material. Currently 10 CFR Part 71 incorporates by reference IAEA Safe Transport of Radioactive Material, SSR-6, 2012 edition, whereas the DOT Hazardous Material Regulations incorporates by reference SSR-6 (Rev 1) 2018 edition. Consequently, DOE applications to DOT must be supplemented to demonstrate compliance to the 2018 edition of SSR-6 (Rev 1).
The NRC engaged with the DOT in the development of a proposed rule, Harmonization of Transportation Safety Requirements With IAEA Standards (opens pdf) to identify and evaluate gaps between 10 CFR Part 71 regulations and the updated IAEA regulations in SSR-6 (Rev 1), 2018 edition. NRC identified 10 regulatory issues for harmonization.
For CAC applications, DOE PCP recommends applicants prepare a stand-alone supplement to their 10 CFR Part 71 Safety Analysis Report for Packaging (SAR/SARP), to address the applicable gaps identified by DOT/NRC between 10 CFR Part 71 and SSR-6 (Rev 1) 2018 edition, and to demonstrate compliance with SSR-6 2018 edition. For packaging that requires ageing management, DOT recommends IAEA SSG-94, Ageing Management and Maintenance of Packages for the Transport of Radioactive Material.
This guidance will likely change when NRC incorporates by reference SSR-6 (Rev 1) 2018 edition in 10 CFR Part 71 and revises Regulatory Guide 7.9 Standard Format and Content of Part 71 Applications for Approval of Packages for Radioactive Material, particularly if NRC does not fully adopt SSR-6 (Rev 1) 2018 edition.
Questions or comments? Contact the DOE PCP Docket Manager, Lawrence F. Gelder [CONTR], (803) 645-3490,
lawrence.gelder@em.doe.gov
Added July 14, 2026