Special Form and IAEA CoCA for Special Form Documentation

This guidance applies only to DOE and DOE Contractors

The main Department of Transportation (DOT) Federal Regulations that apply to special form are:
49 CFR 173.403 Definitions,
49 CFR 173.469 Tests for special form Class 7 (radioactive) materials, and
49 CFR 173.476 Approval of special form Class 7 (radioactive) materials.

Although the definition of special form does not restrict special form to Type A radioactive material, the approved shipping names from the hazardous material table for special form are only for Type A radioactive material (UN3332 and UN3333).  The shipping names for Type B do not contain the words "special form" and they do not list §173.476 as a packaging reference.

49 CFR 173.476(a) requires the offeror to maintain a complete safety analysis, including documentation of any tests, demonstrating that the special form material meets the requirements of §173.469, but it does not require the offeror to obtain a DOT CoCA for special form for domestic transport.  That is, an offeror can make domestic shipment in the US without an DOT IAEA CoCA for special form materials if they maintain the documentation and can provide the documentation to DOT.  However this regulation also states that "An IAEA Certificate of Competent Authority issued for the special form material may be used to satisfy this requirement."  This statement means that an IAEA CoCA for special form issued by DOT or a foreign country is acceptable documentation and the special form radioactive material may be used for domestic shipments in the USA. Many fabricators of special form radioactive material in the United States provide the testing documentation to DOT for review and for DOT to issue an IAEA CoCA.  This process simplifies audits by DOT of fabricators and shippers because DOT maintains copies of the documentation to support IAEA CoCA and therefore the CoCA itself meets the documentation requirement.  

49 CFR 173.476(b) states if the offeror wants to make international shipments the offer needs to obtain an IAEA CoCA for the special form.  This IAEA CoCA may be issued by DOT or by a foreign government.

DOT certificates issued for special form are called "IAEA Certificates of Competent Authority Special Form Radioactive Materials."

IAEA CoCAs for Special Form Radioactive Materials issued either by DOT (the competent authority for USA certificates) or an IAEA CoCAs for Special Form Radioactive Materials issued by the competent authority for a foreign country, provide documentation to support shipments for both domestic and international shipments for all countries.

Updated February 25, 2014

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