A Department Of Energy audit revealed that the Region 8 Radiological Assistance Program (RAP) did not consult Department Of Transportation (DOT) subject matter experts resulting in the incorrect implementation of DOT letters of interpretation. The discrepancy also resulted in a non-compliance with Pipeline and Hazardous Material Safety Administration and Federal Motor Carrier Safety Regulations. The surveillance noted RAP applying a DOT letter of interpretation broadly where transporting hazardous materials on behalf of the federal government was concerned. In fact, the letter provided limited exceptions to the regulations. As a result, the application of the regulations was improper.
Lessons Learned: Radiological Assistance Programs should consult with Department of Transportation experts regarding compliance with requirements and requirements interpretations.
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