Guidance for Shipping Empty Class 7, Certified Type B or Fissile Packaging


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 posted hereexternal (link to DOE Directives website). 

The DOE Packaging Certification Program (PCP) prepared this guidance in response to the following question from the Packaging Management Council in June of 2017: Is a Use/User registration required for shipping empty Type AF or B Containers?

The DOE PCP response and guidance is as follows: Yes.  DOE Order (O) 460.1D, Section 4.a.(2), Requirements for Radioactive Material Packagings, Use of Type B or fissile Materials Certified Packagings, requires Departmental elements when using a Type B or fissile material packaging with contents authorized by a CoC to comply with the conditions of the CoC and register in writing prior to first use.  Once a packaging is placed in service, that is, used to ship radioactive contents, it is no longer non-radioactive and always assumed to contain radioactive contents (albeit residual contents when empty).  In addition, Chapter 7 of a SAR/SARP includes a Section, Preparation of Empty Package for Transport, with specific procedures for preparing the package for shipment in accordance with 49 CFR 173.428, Empty Class 7 (Radioactive) Materials Packaging.  Furthermore, the definition of Use/User in O 460.1D means “The use of certified Type B or fissile material package and packaging includes all package operations, acceptance testing, and maintenance in accordance with the requirements in Chapters 7 and 8 of the SARP and the CoC.” 

    INSTRUCTIONS: Complete the registration form (click here to open the fill-in pdf), sign it, and email it to rampac@srs.gov

    Users or consignors –

    • Must have a 10 CFR 71 Subpart H Quality Assurance Program approved by the DOE HCO.   The steps and process to submit a QAP for HCO approval is posted on RAMPAC QA Frequently Asked Questions .  The status of QAPs approved or under review by the HCO are posted on RAMPAC QA Docket Status.
    • Must register in writing prior to use or consignment of the certified package.  Registration is not complete until PCP approves the registration form and the user is added to the Registered Users Listing page on the RAMPAC website.
    • Obtain permission and the required documentation from the certificate holder for use of the package, including documentation to prepare an empty package for transport, and
    • Make shipments/consignments in accordance with the terms and conditions specified in the certificate, the SAR or SARP of the package design, and the QAP approved by the HCO
    By submitting this form, the applicant is initiating the registration process with DOE PCP to become a user/consignor of the applicable DOE, DOT, or NRC certified Type B or fissile package, and will meet the requirements listed above, prior to use or consignment under the applicable certificate. 

     
    ​Questions or comments? Contact the DOE Packaging Certification Program Manager, Dr. Shuler, (301) 903-5513, james.shuler@em.doe.gov

    Added June 6, 2017



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