Question 53: (a) When a package is properly labeled for
transport, shipping papers are still in effect, and a
transporter has accepted responsibility for control of the
package, do posting and labeling requirements remain in
effect while the package is on licensee property outside of
the radiologically controlled area?
(b) Does the shipment have to be posted in the protected
area?
(c) Does the shipment have to be posted within the
owner-controlled area?
(d) Once the transporter has taken control of a package
and shipping papers are in effect, is the shipment exempt
from posting?
Answer: The answer to all four questions is that the
posting requirements remain in effect until the transporter
has actually taken possession of the package and is
starting to transport it. Following are additional
responses to three of the four specific questions:
a) 10 CFR 20.1905 (d) exempts this package from the
labeling requirements of 10 CFR 20.1904 (a).
(b) Whether or not the package is in a "protected area,"
as defined in 10 CFR 73.2, is not relevant to any
requirements in 10 CFR Part 20.
c) Whether or not the package is in an "owner-controlled
area" (or "controlled area" as defined in 10 CFR Part 20)
is not relevant to the posting requirements of 10 CFR
20.1902 (e).
References: 10 CFR 20.1902 (e), 10 CFR 20.1903, 10 CFR
20.1904 (a), 10 CFR 20.1905 (d))