Hermetically sealed nuclear radiation sensor tubes containing boron trifluoride
Pipeline and Hazardous Materials Safety Administration · May 16, 2007 · Reference No. 07-0089
Interprets: 49 CFR § 171.1
Reggie’s quick take
A company that makes radiation sensor tubes asked PHMSA whether a "specially designed packaging" mentioned in an earlier answer means the outside packaging under Special Permit 12087 or the polyethylene ball inside the power supply/meter. PHMSA's answer is that either one is acceptable for shipping these sealed tubes. The earlier answer said that tubes holding less than one gram of boron trifluoride, sealed and at less than atmospheric pressure, are not subject to the HMR when packaged this way and offered for shipment as the company described.
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 responds to your April 23, 2007 letter requesting further clarification of the packaging requirements for certain hermetically sealed nuclear radiation sensor (detector) tubes containing less than one gram of Boron trifluoride, 2.3, Hazard Zone B, at less than atmospheric pressure under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
In our April 18, 2007 response, we informed you that based on the form and quantity of Boron trifluoride contained in the radiation detector tubes, it is our determination the tubes, when packaged in a specially designed packaging and offered for shipment as described in your letter, will not pose an unreasonable risk to health, public safety or property during transportation and, therefore, are not subject to the HMR. You ask whether our reference to specifically designed packaging refers to the outside packaging described in Special Permit 12087 or the polyethylene ball that is a part of the power supply/meter described in your January 15, 2007 letter. The use of either packaging is acceptable for shipment of the radiation detector tubes.
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.