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 172.101 Hazardous Material Table
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 (UN3333 and UN3329).
The shipping names for type B do not contain the words "special form" and they
do not list 49 CFR 173.476 as a packaging reference.
49 CFR 173.476 (a) requires the offer to maintain documentation 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 offer 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 June 10, 2009