U.S. Nuclear Regulatory Commission

Question 128: If a package containing radioactive material

is to be shipped, and marking the package as low specific

activity (LSA) is the only U.S. Department of

Transportation (DOT) warning requirement, is labeling under

10 CFR 20.1904 (a) required?


Answer: No. Although the exemption of 10 CFR 20.1905 (d)

applies to U.S. Department of Transportation (DOT)

"labeled" containers, not DOT "marked" containers, the

Statement of Considerations, in discussing 10 CFR 20.1905

(d) [56 FR 23380, second column], states that "Quantities

and concentrations not requiring DOT labels would not

warrant an NRC labeling requirement." See also the answer

to Question 36 (10 CFR 20.1906), which indicates that DOT

"marked" packages are not DOT "labeled" packages.

(References: 10 CFR 20.1904, 10 CFR 20.1905).