SED-ESV-2007-0006
REGULATORY REQUIREMENTS
Regulatory History
During the 1960's the rapid increase in the use of freight containers for the consignment of goods
by sea and the development of specialized container ships caused the International Maritime
Organization (IMO) to undertake a study of the safety of containerization in marine transport in
1967. The container itself emerged as the most important aspect to be considered. In 1972, a
conference was held to consider a draft convention prepared by IMO in cooperation with the
Economic Commission for Europe. The conference was jointly convened by the United Nations
and IMO. The 1972 Convention for Safe Containers had two goals. One was to maintain a high
level of safety of human life in the transport and handling of containers by providing generally
acceptable test procedures and related strength requirements which would prove adequate over
years of use. The other was to facilitate the international transport of containers by providing
uniform international safety regulations, equally applicable to all modes of surface transport. In
this way, proliferation of divergent national safety regulations could be avoided.
The requirements of the Convention apply to the great majority of freight containers used
internationally, except those designed specifically for carriage by air. As it was not intended that
all containers, van, or reusable packing boxes should be affected, the scope of the Convention
was limited to containers of a prescribed minimum size having corner fittings - devices which
permit handling, securing, or stacking. The Convention established procedures whereby
containers used in international transport will be safety approved by an Administration of a
Contracting State or by an organization acting on its behalf. The Administration or its authorized
representative will authorize the manufacturer to affix to approved containers a safety approval
plate containing the relevant technical data. The approval, evidenced by the safety approval plate
granted by one Contracting State, should be recognized by other Contracting States. This
principle of reciprocal acceptance of safety-approved containers is the cornerstone of the
Convention; and once approved and plated, it is expected that containers will move in
international transport with the minimum of safety control formalities.
The US accepted the convention requirements and adopted them January 3, 1978. The US
designated the US Coast Guard as the responsible organization to ensure compliance with the
International Convention for Safe Containers (CSC). This was adopted by law and incorporated
into to 49 CFR Parts 450-453. To understand how the requirements of the Convention blend with
the requirements for a radioactive material shipper in the US DOT regulations, a flowchart in
Figure 1 reflects the steps required for using freight containers that meet the ISO 1496-1
Standard.
Present US DOT Regulatory Requirements
In 49 CFR 173.411(b)(6), the present US DOT regulations state:
Freight containers may be used as Industrial packages Types 2 or 3 (Type IP-2) or (Type IP-3)
provided that:
(i)   The radioactive contents are restricted to solid materials;
(ii)   They satisfy the requirements for Type IP-1 specified in paragraph (b)(1); and
(iii)  They are designed to conform to the standards prescribed in the International
Organization for Standardization document ISO 1496-1: "Series 1 Freight Containers--
Specifications and Testing--Part 1: General Cargo Containers; excluding dimensions
and ratings (IBR, see Sec. 171.7 of this subchapter). They shall be designed such that if

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