Instruction IS-39, dated June 10, 2015, from the Nuclear Safety Council, regarding the control and monitoring of the manufacture of packaging for the transport of radioactive material.
http://www.boe.es/boe/dias/2015/07/06/pdfs/BOE-A-2015-7563.pdf
This Instruction aims to detail the procedure to be followed to carry out production conformity for the particular case of containers, packaging, and large packages for bulk (GRG/IBC) and large packagings (which will be encompassed by the term «packaging» in the Instruction) used for the transport of radioactive material and which have package design approval.
Therefore, the Instruction will affect the manufacture of packaging that, according to the dangerous goods transport regulations in force at the time of publication of this Instruction, require package design approval: Type B(U), Type B(M), and Type C packages; packages for the transport of fissile substances and packages containing more than 0.1 kg of uranium hexafluoride.
On the other hand, Royal Decree 97/2014 only defines the control process over packaging manufacturers of the types of packages subject to approval, but not for those packages for which dangerous goods transport regulations do not require such approval: Excepted Packages, of the Industrial type and of Type A. However, considering the importance of package design in transport safety, the CSN considers it necessary for there to be a manufacturing control system for packaging of these types of packages, weighed against their lower risk.
For these packages, there is no approval certificate issued by the competent authority, and it is sufficient for the consignor to provide, if required, documentary evidence demonstrating that the package design meets the requirements of the dangerous goods transport regulations. However, this regulation does not specify how this compliance documentation should be, and consequently, there is no clear reference for possible subsequent control of packaging manufacturing. Therefore, this Instruction also aims to indicate the aspects to be taken into account in the development of this documentation and defines its generic structure.
Consequently, the second objective of this Instruction is to define the procedure for carrying out production conformity in the case of packaging used for the transport of radioactive material that do not require package design approval and to specify the minimum content of the documentary evidence that the package design complies with regulatory requirements and which will serve as a reference for checking production conformity in the manufacture of packaging.
The production conformity control procedure for the manufacture of packaging not subject to design approval is adapted in the Instruction to the lower risk of the radioactive material they can transport compared to the case of packages subject to approval, allowing for the alternative that production conformity be carried out by the purchaser of the packaging or that they may use an OC.