American Portable Nuclear Gauge Association
This is a stand-alone version from the Training Manual. For the full length training manual click here.
To help you understand the requirements of HAZMAT shipping we have developed a step-by-step approach that starts at the storage area and moves to the preparation of the gauge and case.
Typically you will be shipping the gauge to:
- The worksite – If you are transporting your gauge to a worksite you are considered to be a private shipper and must prepare all of the paperwork and packaging by yourself. If you are transporting the gauge directly to a gauge service/repair facility you will likewise prepare the paperwork. The service/repair facility may still need you to obtain a return authorization before they accept it. Check the website of the facility regarding their requirements.
- Service provider – If you are sending your gauge in for service or calibration and are using an independent ground transport common carrier or air cargo transport you will have to prepare the documents and package for them. The service/repair facility will require you to obtain a return authorization before they will accept the gauge. Most service/repair facilities have a website with directions for shipping a gauge.
- A disposal facility – Follow the procedures for sending the gauge in for service/repair but pre-arrange the disposal, including any cost of disposal. Make sure the disposal company sends you documentation that the gauge has been permanently transferred. Make sure to adjust your inventory.
Step 1) Checking the Condition of the Gauge:
Decide which gauge in the storage area you will be shipping.
Make sure the gauge is undamaged and operational. Is it charged? Turn it on and make sure the display appears.
A quick test will determine if the sliding block mechanism is fully functional. While the gauge is sitting flat on the floor put the source rod in the backscatter position and then raise it back into the safe position. Use a survey meter to make sure the sliding block is fully closed. Turn it on and point it at the base of the gauge where the source rod resides. At one meter away the reading should pretty much match the number on the Yellow Radioactive II sticker, known as the transport index number – it should read less than one millirem. At the surface of the gauge the reading should be <20mrem per hour.
How does the gauge case look, inside and outside? Are there any holes, cracks or areas where the plastic has worn away? Are the clasps in undamaged condition? If there is any damage you can’t use that case.
Does the gauge have a lock on the handle? Is there a lock on the outside hasp?
How do the labels look? Can you read all the information contained on all labels? If not, you need to replace the label.
Is there a current leak test on the gauge?
If everything checks out write down the serial number of the gauge.
Step 2) Understanding the Labels and Documents – Preparing the Paperwork:
Before you remove the gauge for transport you must first prepare bill of lading and emergency response documents. This section will discuss these documents and how to prepare them.
Communicating the Hazards
Labels and documents are used to communicate the hazards associated with portable nuclear gauges. Shippers and emergency response individuals are trained to recognize this information and take the necessary precautions. Examples of these labels and documents with explanations of the information are described below.
A properly labeled gauge case will display one Type “A” Package Label on one of the broadsides of the case and situated next to a Yellow Radioactive II label. There must be two Yellow Radioactive II Labels on opposite broadsides. There must also be two Air Cargo Only Labels on opposite broadsides. These labels must always be in legible condition.
The Type “A” Package identifies the type of case you are using to store the gauge as well as identifying information in the event of emergency response. It should be placed on one broadside of the gauge case next to one of the Yellow Radioactive II Labels and be in legible condition.
Information on the Type “A: Package Label includes:
- UN3332 – UN Identification Number – This universal reference number lets emergency response personnel know exactly the type of material that you are transporting. A future requirement states that this number must precede the other identifying information on your labels and papers. Moisture density gauges have been assigned UN3332 – individuals will cross-reference this number to determine the hazardous material.
- USA DOT 7A Type “A” Package – Refers to the case the gauge is shipped in. The case must meet integrity tests before qualifying for this designation. Type “A” Package documentation must be kept on file. This document will be discussed later in this section.
- Radioactive Material – Proper Shipping Name – The proper shipping name for the gauge.
- Special Form – This identifies the physical form of the radioactive sourcesinside the gauge.
- RQ – Reportable Quantity – Abbreviated as RQ, the EPA has set threshold limit levels that, if exceeded, must be indicated at the end of the Proper Shipping Name. The limit for Americium 241 is 10mCi. Because moisture density gauges use more than 10mCi (usually 40-50mCi) of Am241 the designation RQ must be shown (If you are using a gauge that only has a density/gamma source it will not have to show the RQ).
The above label and information tells the handler you are shipping Radioactive Material in aType “A” Package, Special Form, RQ.
The Radioactive II Label identifies the gauge as a Hazard Class 7 Radioactive Device. The label must list the type of radioactive materials contained in the gauge as well as the quantity of each radioactive material. A Transport Index number must also be displayed. The case requires two of these labels on opposite broadsides of the gauge case.
An explanation of the required information is as follows:
- Contents – the abbreviated names of the radioactive materials
- Activity – The activity of the radioactive materials must be in SI units (becquerels) but can also list the equivalent millicuries.
- Contents Cs137/Am241
- Activity 0.30 GBq (8.0mCi) /1.48 GBq (40.0 mCi)
- Transport Index – usually handwritten in the box – typically in the 0.2 – 0.7 range. Use the number that originally came with the gauge or contact the manufacturer for the correct number. This number informs the handler that at one meter away the exposure rate from the gauge per hour is the number listed in the box.
The “Air Cargo Only” labels inform the handler that gauges cannot be transported on passenger aircraft. There must be two labels, one on each broadside.
Shipping documents must also communicate the hazards associated with portable nuclear gauges. Every time you “ship” a gauge to the work site, or turn your gauge over to a shipper for delivery, you must prepare a bill of lading.
There are three versions of the bill of lading. There is a private carrier bill of lading, used when you take the gauge to the worksite, a ground transport bill of lading when shipping by ground transport and an air transport type of bill of lading, also known as a dangerous goods statement.
The bill of lading must be accompanied by an Emergency Response Sheet.
Private Carrier Bill of Lading
This is the type of bill of lading you will use whenever you transport the gauge on a public roadway. It doesn’t matter if you are going to the worksite, the FEDEX office or a gauge service center. You can create your own document. There is no official private carrier document already prepared for you. It’s a do-it-yourself-document. The bill of lading document must contain specific information about you and your gauge. Include the following:
- Type the information on company letterhead.
- Type the words “Bill of Lading” under your letterhead.
- Date: 2/1/20**
- Type your company name and address:
- Shipper: APNGA Paving
- 1234 Gauge Road
- Rockroad, MD 12345
- In the body of the document type the following line of information about your gauge:
- “UN3332, Radioactive Material, Type A Package, Special Form, 7, RQ”
- Gauge Manufacturer, Model & Serial Number
- Cs-137, 0.30 GBq (8 mCi)
- Am-241, 1.48 GBq (40 mCi)
- Radioactive Yellow II Label, TI = 0.5
- Emergency Gauge Manufacturer Contact Telephone Number: 301-123-4567
- Company RSO Telephone Numbers: 123-456-7890, 234-567-8901
- US DOT Emergency Number: 800-424-8802
- US NRC Emergency Number: 301-816-5100
- Agreement State Emergency Number: 123-456-7890
- The authorized person preparing the document print and sign their name.
The following information describes the information listed on the above bill of lading:
- This info UN 3332 Identification Number – This universal reference number lets emergency response personnel know exactly the type of material that you are transporting. A future requirement states that this must precede the other identifying information on your papers – you may as well start doing it now.
- Proper Shipping Name – The proper shipping name for moisture density gauges is “Radioactive material”:
- Type A package – This describes the case the gauge is stored/shipped in.
- Special Form – This identifies the physical form of the encapsulated sources.
- 7 –This is the hazard class for radioactive material.
- RQ – Reportable Quantity – Abbreviated as RQ, the EPA has set threshold limit levels that, if exceeded, must be indicated at the end of the Proper Shipping Name. The limit for Americium 241 is 10mCi. Because moisture density gauges use more than 10mCi (usually 40-50mCi) of Am241 the designationRQ must be shown (If you are using a gauge that only has a density/gamma source it will not have to show the RQ).
So, the above bill of lading and information tells the viewer you are shippingRadioactive Material in a Type “A” Package, Special Form, 7, RQ.
The next section of the bill of lading lists the gauge manufacturer, gauge model and serial number. Although not technically required this information could be invaluable when describing the gauge to emergency response individuals.
The next section of the bill of lading describes the:
- Radionuclide name and activity – Your shipping papers must list the name of each radioactive material and its activity. The activity must be expressed in becquerels with the equivalent millicurie in parenthesis. Examples:
- Cs-137, 0.30 GBq (8 mCi)
- Am-241, 1.48 GBq (40 mCi)
The next requirement describes the:
- Radioactive Label Category – Radioactive materials are categorized by their level of activity, Radioactive l-White, Radioactive ll-Yellow or Radioactive lll-Yellow. The higher the activity, the higher the category number. The radioactive label for moisture density gauges is:
- Yellow Radioactive ll
- Transport Index – Also known as “TI”. The transport index box is located on the Radioactive Yellow ll label. This box will have a number written inthat tells the viewer what their radiation dose rate will be, in millirems, if they were to sit for one hour at one meter away. It is an easy way for the handler/shipper to know how radioactive the package is. The “TI” will already be designated and written on the label when you first receive the gauge. If the label needs to be replaced you will want to enter this same number on the new label. The TI number for moisture density gauges will usually be in the range of 0.2 – 0.7. Example:
- TI = 0.5
Next bill of lading requirement:
- Emergency Contact Number – Every license holder should have a 24 hour emergency contact telephone number for a competent emergency response source. The source should have first-hand knowledge about the gauge and be able to give comprehensive emergency response information, specifically the steps to be taken for remediation and control measures involving gauges whose integrity have been compromised in an accident or fire. Gauge manufacturers supply a contact number for this purpose. Make sure that the contact complies with your agency’s regulations. This emergency contact number should be listed on the bill of lading and emergency response sheet.
- APNGA also recommends listing emergency contact numbers for the RSO, USDOT, NRC and Agreement State.
- An example of a private carrier bill of lading can be found in the appendices.
The above information will be repeated if preparing transport document to be sent by a ground transport shipping company or cargo air transport company. Always try and use the documents of the shipping company. They can usually be accessed and filled out on their websites. Additional information will be required as follows:
Shipping paper certification statements
This statement, which is stated at the bottom of a common carrier or air transport shipping company bill of lading, commits you to providing a package whereby you state “I hereby declare that the contents of this consignment are fully and accurately described above by proper shipping name, and are classified, packaged, marked and labeled, and are in all respects in proper condition for transport according to applicable International and National Governmental Regulations”. If your gauge is being shipped by air you must also add the line “I declare that all of the applicable air transport requirements have been met”. Most trucking and air transport forms have already listed these statements for you.
Notice the shipper certification at the bottom of the page.
Make sure you verify the identity of the common carrier.
Air transport – You cannot ship your gauge on a passenger aircraft. Your best option is FEDEX. FEDEX only ships by cargo aircraft and can ship your gauge anywhere overnight (if necessary). Their form will require the same content as seen on the private carrier and common carrier documents. It must also include gauge case dimensions (include metric dimensions). It must also state that “All packed in one Type A package”. Their dangerous goods statement, known as a “Declaration of Dangerous Goods Document” meets the requirements of the IATA (International Air Transport Association). It is accessible on their website, making it easy to type in the fields and print out the document. It also includes the required statement “Cargo Aircraft Only”.
Make sure to pay close attention to filling out the forms. FEDEX is not allowed and will not make corrections for you.
You should print out 3 copies of the document. Make sure you print the documents on a color printer since the candy striped slashed borders must show up red. You will also need to fill out a normal air waybill. The gauge case must your company name, address and phone marked on it. Make sure to keep a copy of these documents on file. The FAA, a division of the USDOT, may very well contact you in the future for a copy of these documents. They will also want to see a copy of your license and your training certificates.
If you are shipping your gauge outside of the US you will need to use the shipping documents provided by the air cargo shipper. The required information will be the same as domestic shipments but, because the shipment will likely be turned over to a forwarder, you will need to supply the forwarder a “Letter of Instruction”, who will act to complete further Air Waybills for you. International shipments must also include a copy of the gauge Certificate of Competent Authority.
Emergency Response Information Sheet
This is the other document, along with the bill of lading, that you must have direct access to whenever transporting a gauge. Slide them back-to-back in a plastic sleeve and place them in the seat beside you or in the driver side door slot. The emergency response sheet is very similar to a MSDS sheet. It lists the potential hazards of radiation as well as the emergency actions you would take in the event of an accident or fire. It lists first aid measures you would take and includes the 24 hour emergency contact number. These information sheets are readily available through the manufacturer and should contain the following:
- Hazards to health
- Fire or explosion risks
- Accident precautions
- Emergency actions for fires
- First aid
- Emergency contact numbers – response personnel should be able to provide information regarding hazards and risks, emergency response and accident mitigation
Direct access also means readily viewable, meaning that the documents cannot be placed in the gauge case, glove compartment or trunk. Emergency response personnel know to look for HAZMAT information on the passenger seat or document holder on the driver side door. If you leave the vehicle place the documents on the driver’s seat. Check with your licensing agency for any other requirements.
Keep copies of the bill of lading and emergency response sheets on file for three years after the shipment. You can use the same documents for multiple shipments provided you keep a log of the different shipping dates. Each gauge must have its own set of documents.
Step 3) The Type “A” Package Gauge Case
The gauge case is known as a Type “A” Package. The gauge must be transported in this case. You cannot transport a gauge in a self-made box or crate. All Type “A” Packages/Cases must pass a series of tests that ensure their integrity. These tests include water spray testing, free drop testing, a stacking test and a penetration test.
Each manufacturer uses their own unique Type “A” Package. You can download a copy of the Type “A” Package document from the manufacturer website or contact them for a copy. The documentation must be kept on file up to three years after the last shipment.
If you use an overpack (a cardboard carton to ship the gauge and case in) you must also place two Yellow ll Radioactive and two Air Cargo Only labels on the broadsides. You must also mark the carton as an “Overpack”.
The gauge and the case must be inspected before it is signed out of storage. Make sure the case is not cracked or damaged in any way, including hinges and hasps, make sure that all labels and markings are affixed and legible, and make sure the release mechanism on the gauge handle and the case is locked.
If you are shipping the gauge to the worksite make sure you abide by all of the rules of HAZMAT security and surveillance. Make sure to have a copy of operating and emergency procedures.
If you are turning your gauge over to a common carrier ground transport company or air transport cargo service make sure to verify their identity. The shipping company is relying on you to have all of your documentation in order. They cannot correct any of your mistakes. Your gauge will be returned to you if the paperwork or package is not in order.
Always remember to sign the gauge out on the daily utilization and inventory forms.
Gauges can only be transferred to companies or individuals specifically licensed to possess them. Verification of the transferor’s and transferee’s authorization to possess radioactive material must be documented. A copy of each other’s radioactive materials license must be exchanged and the transferor’s license must be retained on file as evidence of an authorized transfer.
At a minimum the transfer documentation must include:
- The material being transferred (gauge manufacturer name, model and serial number, type and activity of the radioactive material, and source manufacturer name and serial numbers.
- The date of the transfer.
- The name, address, and license number of the transferor and transferee.
- The signatures of the individuals shipping and/or receiving the gauge.
- A current leak test.
- All transfer records will be kept on file for inspection.