Basic philosophy

Paragraph 101 of TS-R-1 specifically states that the Regulations:

“…establish standards of safety which provide an acceptable level of control of the

3Emphasis of bolded text added for benefit of this training manual.

radiation, criticality and thermal hazards to persons, property and the environment that are associated with the transport of radioactive material.” This paragraph goes on to indicate that because the Regulations utilize the principles set forth in basic IAEA radiation protection documents, “compliance with these Regulations is deemed to satisfy the principles of the Basic Safety Standards in respect of transport.”

The Regulations are fundamentally based on the philosophy that radioactive material being transported should be adequately packaged to provide protection against the hazards of the material under all conditions of transport, including foreseeable accidents. The Regulations place the duty of providing adequate packaging upon the consignor of the material. This is accomplished by making safety a priority in the package design requirements. Through this fundamental philosophy, dependence on careful and proper actions by the carrier is minimized. However, this does not relieve the carrier from all responsibilities.

In addition, paragraph 105 of TS-R-1 indicates that “the safety of persons, who are either members of the public or workers, is assured when these Regulations are complied with,” and that “confidence in this regard is achieved through Quality Assurance and Compliance Assurance programmes.” Thus, Quality Assurance and Compliance Assurance become key links in the safety chain established by the requirements in the Regulations.

In summary, the philosophy of the Regulations is that, as far as possible:

(1) Packages of radioactive material should be dealt with in the same way as other hazardous goods;

(2) Safety depends primarily upon the package and not on operational controls;

(3) The consignor should be responsible for ensuring safety during transport through proper characterization of the contents, proper packaging of those contents, and proper operational actions including adequate communications. Communications in this context include shipping papers, marking, placarding and labelling, transport indexes, criticality safety indexes, approval certificates, proper shipping names and UN numbers.

Again, this philosophy was developed so that the safety burden would be placed upon the proper preparation of consignments rather than actions required of carriers. The intent of the Regulations is that consignments of radioactive material can be transported with minimal special handling. Basic safety concepts associated with the Regulations are discussed further in Chapter 5.

Because of the robust nature of the packaging requirements in the Regulations, transport industry workers are expected to treat radioactive material consignments with care, but with no more care than that accorded to other dangerous goods.

Since the Regulations are, for administrative purposes, "model regulations"

recommended by the IAEA to Member States and appropriate international organizations, they need to be practical with respect to what the various parties involved are required to do.

This means that they must be structured to facilitate their conversion into the format and

"language" used by the regulators in multiple countries and for various modes of transport.

In addition, the Regulations must be clear and concise, stating "what" has to be achieved. In other words, they are performance based rather than prescriptive. It was decided decades ago to formulate them in this fashion rather than specifying "how" to achieve the

desired degree of protection in terms of detailed design specifications. The Regulations also do not generally explain "why" a given requirement is imposed or why it should be achieved.

1.6.3. Scope

The scope of the Regulations is clearly specified in paragraphs 106-109 of TS-R-1.

These paragraphs define the range of applicability of the Regulations.

In summary, the Regulations apply to:

(1) The transport of radioactive material by all modes on land, water or in the air,

(2) Any transport which is incidental to the use of the radioactive material (paragraph 106 of TS-R-1).

In this context, transport comprises all operations and conditions associated with, and involved in, the movement of the radioactive material including the:

(1) Design of the package;

(2) Manufacture, maintenance, and repair of the packaging; and

(3) Preparation, consigning, loading, carriage (including in-transit storage), unloading and receipt at the final destination of loads of radioactive material and packages.

As already noted, the Regulations utilize a graded approach that is applied to the performance standards. This graded approach is characterized by three general performance levels that relate to the design of the package (paragraph 106 of TS-R-1):

(1) Routine conditions of transport (incident free), (2) Normal conditions of transport (minor mishaps), and (3) Accident conditions of transport.

In contrast, paragraph 107 of TS-R-1 specifies that the Regulations do not apply to five different types of material:

(1) Radioactive material that is an integral part of the means of transport (such as depleted uranium counterweights in aircraft);

(2) Radioactive material moved within an establishment that is subject to appropriate safety regulations in force in the establishment and where the movement does not involve public roads or railways;

(3) Radioactive material implanted or incorporated into a person or live animal for diagnosis or treatment (such as a cardiac pacemaker, or radionuclides injected into a person for medical purposes);

(4) Radioactive material in consumer products that have received regulatory approval, following their sale to the end user (such as smoke detectors);

(5) Natural material and ores containing naturally occurring radionuclides which are not intended to be processed for use of these radionuclides provided that the activity concentration of the material does not exceed ten times the values specified (paragraphs 401-406 of TS-R-1).

There are two other areas related to the scope of the Regulations; one deals with controls on shipments, and the other deals with subsidiary risks of the contents of consignments.

Controls on shipments relating to routeing or physical protection, which may be imposed by various governmental agencies for purposes other than radiological safety are not specified in the Regulations (see paragraph 108 of TS-R-1). However, the Regulations note that such controls must not detract from the standards of safety for which the Regulations have been developed relative to the radiological hazards posed by the contents of the package.

Relative to subsidiary risks, the Regulations simply state (see paragraphs 109 and 507 of TS-R-1) that all “relevant transport regulations for dangerous goods of each of the countries” involved in the transport “shall apply in addition to” the Regulations.

1.6.4. Units

Prior to the 1985 Edition of the Regulations, the “conventional” system of units was used. For example, activity was specified in curies (Ci), and radiation levels in rems.

Transition from the conventional system to the SI system of units occurred in the 1985 Edition of the Regulations. For example, activity is specified in becquerels (Bq), and radiation levels in sieverts (Sv). In the 1985 Edition, the SI units were controlling and the conventional units were shown in parentheses and generally were rounded down from the SI units. In the 1996 Edition of the Regulations, the only units used are those of the SI system.