U.S. Nuclear Regulatory Commission

10 CFR 20.203 (f) Enforcement Guidance for Container Labels

HPPOS-027 PDR-9111210147

Title: 10 CFR 20.203 (f) Enforcement Guidance for

Container Labels

See the memorandum from A. F. Gibson to Radiation Support

Section dated March 7, 1980. This memo contains

enforcement guidance for container labels in 10 CFR 20.203

(f) and states that the purpose of labels is to ensure

adequate information is available to enable a worker to

handle the materials safely. The health physics position

was written in the context of 10 CFR 20.203, but it also

applies to the "new" 10 CFR Part 20, Sections 20.1904 and

20.1905. HPPOS-028 contains a related topic.

A label required pursuant to 10 CFR 20.203 (f) [and 10 CFR

20.1904] must bear the radiation caution symbol and the

words "CAUTION, RADIOACTIVE MATERIAL" or "DANGER,

RADIOACTIVE MATERIAL", as well as provide sufficient

information that includes the radiation levels, kinds of

material, estimates of activity, date the activity was

estimated, mass enrichment, etc. This is required to

permit individuals handling or using the container or

working in the area to take necessary precautions to avoid

or minimize exposure and ensure worker safety.

Unlabeled containers are almost a certainty in any large

facility, such as a power plant. If the discovery of

unlabeled containers constitutes isolated occurrences,

enforcement action may not be appropriate. However, a very

high radiation level container left unlabeled would be a

safety hazard, as well as a strong indicator of a defect in

the licensee's radioactive materials control program.

Should noncompliance with 10 CFR 20.203 [or 10 CFR 20.1904]

be suspected, it must be determined whether control is

being exercised by other methods described in 10 CFR 20.203

(f) (3) [or 10 CFR 20.1905]. In addition, the calculations

used to determine greater than Appendix C quantities

present in the container should be included in the

discussion section of the Inspection Report. It must be

emphasized to the licensee that the purpose of 10 CFR

20.203 (f) [and 10 CFR 20.1904] is to ensure adequate

information is available to workers to enable them to

safely handle radioactive materials and minimize exposure.

Regulatory references: 10 CFR 20.203, 10 CFR 20.1904, 10

CFR 20.1905

Subject codes: 4.7, 12.7

Applicability: All