United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

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)









Page Last Reviewed/Updated Thursday, March 29, 2012