The NRC issued generic letter STC-18-037 “Applicability of U.S. Department of Transportation Requirements to Class 7 (Radioactive) Material Transport, and When to Request an Exemption from 10 CFR 71.5(b)” on June 1, 2018 explaining how the U.S. Department of Transportation (DOT) regulations in Title 49 of the Code of Federal Regulations (CFR) are incorporated into U.S. Nuclear Regulatory Commission’s (NRC’s) transportation regulations in 10 CFR Part 71, “Packaging and Transportation of Radioactive Material,” and how they apply to Agreement States. It also informs the Agreement State programs that NRC and Agreement State licensees are required to follow the standards and requirements of the DOT regulations in 49 CFR applicable to Class 7 (radioactive) material transport. These requirements apply even for shipments not covered by DOT regulations, unless the licensee requests an exemption from 10 CFR 71.5(b) or the Agreement State’s equivalent regulation. The purpose of 10 CFR 71.5(b) is to impose, by NRC authority, pertinent DOT requirements for shipments of Class 7 (radioactive) material by NRC licensees even when those shipments do not enter commerce.

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STC-18-037_explains 10CFR71.5b applicability