U.S. Nuclear Regulatory Commission
Question 128: If a package containing radioactive material
is to be shipped, and marking the package as low specific
activity (LSA) is the only U.S. Department of
Transportation (DOT) warning requirement, is labeling under
10 CFR 20.1904 (a) required?
Answer: No. Although the exemption of 10 CFR 20.1905 (d)
applies to U.S. Department of Transportation (DOT)
"labeled" containers, not DOT "marked" containers, the
Statement of Considerations, in discussing 10 CFR 20.1905
(d) [56 FR 23380, second column], states that "Quantities
and concentrations not requiring DOT labels would not
warrant an NRC labeling requirement." See also the answer
to Question 36 (10 CFR 20.1906), which indicates that DOT
"marked" packages are not DOT "labeled" packages.
(References: 10 CFR 20.1904, 10 CFR 20.1905).