Guidance for DOE Use of DOT-IAEA Certificates
This guidance applies only to DOE and DOE Contractors
This guidance does NOT apply to any company that has a contract with the DOE, but is licensed by the NRC and has a QA program approved by the NRC. (See 10 CFR Part 71.0, Purpose and scope and 10 CFR Part 71.3, Requirement for License.) The company conducts operations under its license with the NRC and is subject to audits by the NRC. A contractor in this group would need to be listed as a user on the DOT Certificate.
DOT issues USA IAEA Certificates for shipments from the United States toother countries based on "certified" USA packagings and for shipmentsto the United States based on Certificates from other countries. USA-"Certified" packagings can be based on
- NRC Certificates,
- DOE Certificates,
- Special Form Certificates from DOT, and
- DOT Specification packagings described in 49 CFR Parts 100-185.
All hazardous material shipments made by DOE Contractors areofficially DOE shipments. That is, the shipments are made for DOE. DOE contractors are required by DOT to be registered with DOT if they makehazardous material shipments in commerce. DOE contractors can only ship under a DOT-IAEA Certificate only if DOE is listed as "certificate holder" or as a "registered user." However, if a DOE Contractor intends to ship under a DOT-IAEA Certificate, the contractor must register directly with DOT as a user. To determine if DOE is a registered user of a DOT-IAEA Certificate, see Points of Contact.
- DOE is a Registered User: The prospective User must contact the certificate holder to obtain packaging(s) and documentation necessary to utilize the DOT Certificate.
- DOE is not a Registered User: The prospective User must submit a request to Manager, Packaging Certification Program (PCP) via his respective DOE field office, asking the DOT to add DOE as a registered user. The Manager, Packaging Certification Program will forward the request to the DOT, will notify the DOE field office when DOE has been registered as a user, and will update the Points of Contact page accordingly.
Registration with the Packaging Certification Program prior to use a DOT-IAEA Certificate: DOT does not require contractors who plan to utilize a DOT-IAEA Certificate to register with PCP prior to first use. However, PCP recommends those who intend to utilize DOT-IAEA Certificates provide a copy of the "registered user" application to the respective DOE field office.