Definition of Radioactive Material Starter Bottle
Pipeline and Hazardous Materials Safety Administration · Jul 13, 2001 · Reference No. 01-0107
Interprets: 49 CFR § 173.403
Reggie’s quick take
A company asked whether a light bulb with a glass starter bottle coated with a radionuclide solution counts as Class 7 (radioactive) material under § 173.403. The letter says the specific activity is figured using only the weight of the coating, not the whole coated bottle. If it is 70 Bq per gram or lower, the bulb is not Class 7 and is not subject to the Hazardous Materials Regulations for transport. If it is higher, the bulb may be shipped as a limited quantity or surface contaminated object in an excepted package. The letter covers transport only and points to Nuclear Regulatory Commission rules in Title 10 for use, possession and disposal.
Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.
This is in response to your April 30, 2001 letter inquiring whether your light bulb meets the definition of a Class 7 (radioactive) material under 49 CFR 173.403. The light bulb contains a glass "starter bottle." The bottle's interior surface is coated with a solution containing a radionuclide. Specifically, you ask whether the specific activity is calculated by using the entire weight of the coated starter bottle or by using the actual weight of the coating.
The specific activity is calculated by using the actual weight of the coating on the starter bottle. If the specific activity is 70 Bq per gram or lower, the light bulb does not meet the definition of Class 7 (radioactive) materials and is not subject to the Hazardous Materials Regulations. If the specific activity is greater than 70 Bq per gram, you may be able to offer the light bulb for transportation as a limited quantity material or surface contaminated object in an excepted package.
This information addresses only the transportation of the light bulbs in question. We suggest that you review the U.S. Nuclear Regulatory Commission regulations in Title 10 of the Code of Federal Regulations regarding the use, possession and disposal of these light bulbs.
I trust you find this information helpful.
A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.