Question 127: 10 CFR 20.1904 (a), Labeling containers,
indicates in a parenthetical statement that "the
radionuclides (s) present" may now be intended to be a part
of the information required to be included on labels. In
reply to comments on this rule, the preamble (56 FR 23380,
first column) provides a special interpretation for nuclear
power plant licensees as to acceptable methods for
compliance for labeling fission and activation product
containers. Taken together, the rule and preamble can be
understood to mean that nuclear power plant licensees are
required by the revised Part 20 to include the words
"activation products" and/or "mixed fission products" on
all containers in which greater than an Appendix C quantity
is present - a considerable undertaking which would not
contribute appreciably to radiation protection. Do the
words "such as" in the parenthetical statement mean that
this interpretation is incorrect?
Answer: Yes. This interpretation of the rule and preamble
is incorrect. The parenthetical statement provides
examples of the types of information that may be included
on the label; it is not a requirement to include all of the
information in the parenthetical statement. However, 10
CFR 20.1904 does require the label to include sufficient
information to permit individuals handling or using the
containers, or working in the vicinity of the containers,
to take precautions to avoid or minimize exposures. Simply
having only "Caution, Radioactive Material" or "Danger,
Radioactive Material" on the label is not sufficient.
(Reference: 10 CFR 20.1904)