Excepted Packages: When and How to Ship Radioactive Material

Why Excepted Packages Matter

Not every radioactive shipment needs the full treatment. Many facilities ship low-activity items—check sources, reference standards, calibration devices, empty containers—that fall well below the thresholds for Type A or Type B packaging. When your material qualifies as an excepted package, the regulatory burden drops significantly.

I have seen facilities ship small check sources in full Type A spec packaging with YELLOW-II labels, a detailed shipping paper, and a 24-hour emergency phone contract—all for a source that easily qualified as a limited quantity under UN2910. The kicker was the carrier charged a hazmat surcharge that could have been avoided entirely. The shipper didn't realize their material was well below the excepted limits, so they defaulted to the full treatment. That's money and time spent for no reason.

The difference is substantial. A fully labeled RAM shipment requires radioactive labels, a Transport Index calculation, a detailed shipping paper with activity and physical form, a 24-hour emergency phone number, and carriers trained and willing to handle it. An excepted package needs a UN number on the outside, a simplified shipping paper, and a package that meets basic design standards. Understanding when you qualify for excepted shipping isn't just regulatory knowledge—it's a practical skill that saves real time and money.

Who Needs to Know This

This applies to anyone who:

• Ships low-activity sealed sources, check sources, or reference standards
• Returns empty containers that previously held radioactive material
• Ships instruments or devices containing small radioactive sources
• Works with manufactured articles made from depleted uranium or natural thorium
• Classifies outbound RAM shipments and selects the appropriate UN number

The Four Types of Excepted Packages

DOT recognizes four categories of excepted packages, each with its own UN number and qualifying conditions. The type you use depends on what you're shipping.

UN2908 — Empty Packaging

Covers packages that previously contained radioactive material and have been emptied as far as practical. Under 49 CFR 173.428, the package must be securely closed, in unimpaired condition, and internal contamination must not exceed 100 times the limits in 49 CFR 173.443(a). Any previous radioactive labels must be removed or covered, and an “Empty” label applied per 49 CFR 172.450.

Most of the time, the packages you're returning as empty are the same containers that came to you with a source in them. Keep in mind that just because the source has been removed doesn't mean the container is ready to ship as UN2908. You still need to survey for contamination and verify dose rates. One thing I see overlooked frequently is the internal “Radioactive” marking requirement—people focus on the outside of the package but forget that the word “Radioactive” needs to be visible on the inside when the package is opened.

UN2909 — Manufactured Articles (Natural Uranium, Depleted Uranium, or Natural Thorium)

Under 49 CFR 173.426, this covers manufactured articles—like counterweights, shielding components, or ballast—made from unirradiated natural uranium, depleted uranium, or natural thorium. The uranium or thorium must be enclosed in an inactive sheath of metal or another durable protective material. These articles must not have been irradiated or processed beyond what's needed for the manufactured product.

UN2910 — Limited Quantity of Material

The most commonly used excepted category for active material. Under 49 CFR 173.421, this applies when the activity in a package does not exceed the limited quantity limits specified in Table 4 of 49 CFR 173.425. The limits depend on the physical state (solid, liquid, gas) and form (special or normal) of the material. Common items that qualify include small check sources, low-activity calibration standards, and reference samples.

UN2911 — Instruments or Articles

Under 49 CFR 173.424, this covers radioactive material that is an integral part of an instrument or manufactured article. The radioactive component must be completely enclosed by non-active components, and the radiation level at 10 cm from the surface of the unpackaged instrument must not exceed 0.1 mSv/h (10 mrem/h). Activity limits apply both per individual instrument and per package, using the instrument/article columns in Table 4 of 49 CFR 173.425. These limits are generally more generous than limited quantity limits because the enclosure provides additional shielding and containment.

The most common UN2911 shipments I see are portable survey meters with small check sources built in, moisture density gauges, and static eliminators used in industrial settings. Smoke detectors containing Am-241 are another classic example when shipped in commercial quantities. If the source is an integral part of the device and completely enclosed by the device housing, you're likely looking at UN2911 rather than UN2910.

Activity Limits: The Numbers That Determine Qualification

The activity limits for excepted packages are defined in Table 4 of 49 CFR 173.425. The limits are expressed as fractions of the A₁ and A₂ values for your radionuclide, and they depend on three factors:

1. Physical state: Solid, liquid, or gas
2. Form: Special form or normal form
3. Excepted type: Limited quantity (UN2910) vs. instrument/article (UN2911)

Limited Quantity Limits (UN2910)

For limited quantities, the package activity limits are relatively conservative:

• Solids, special form: 10⁻³ × A₁ per package
• Solids, normal form: 10⁻³ × A₂ per package
• Liquids: 10⁻⁴ × A₂ per package (ten times lower than solids)
• Gases: 10⁻³ × A₁ or A₂ per package (depending on form)

Instrument/Article Limits (UN2911)

Instruments and articles get two sets of limits—per individual item and per package:

• Per instrument (solids): 10⁻² × A₁ or A₂
• Per package (solids): A₁ or A₂ (the full value)
• Per instrument (liquids): 10⁻³ × A₂
• Per package (liquids): 10⁻¹ × A₂

Notice the difference: the per-package limits for instruments are significantly higher than for limited quantities. A package of instruments in solid special form can contain up to the full A₁ value—1,000 times more than a limited quantity package of the same material. This is because the non-active enclosure of the instrument provides inherent containment and shielding.

Dose Rate and Contamination Requirements

Meeting the activity limits alone doesn't qualify your package as excepted. You also need to meet dose rate and contamination standards.

Surface Dose Rate

For all excepted packages, the radiation level at any point on the external surface must not exceed 0.005 mSv/h (0.5 mrem/h). Compare this to labeled packages, which can have surface dose rates up to 2 mSv/h (200 mrem/h) for YELLOW-III. The excepted package limit is 400 times lower.

The most common mistake I see is shippers not surveying the entire package surface. They'll take a reading on the top or the front and call it good. The regulation says “any point on the external surface,” and 0.5 mrem/h is a very low threshold. Keep in mind that if the source is positioned toward one side of the package, you might get 0.3 mrem/h on one side and 0.7 mrem/h on the other—which would disqualify the package. Always survey all six sides.

Contamination Limits

Non-fixed (removable) contamination on the external surface of any excepted package must not exceed the limits in 49 CFR 173.443(a). For empty packages (UN2908), internal contamination must not exceed 100 times those same limits.

What's Reduced: Excepted vs. Labeled Packages

The practical benefit of excepted classification is the list of requirements you don't have to meet. Here's the comparison:

I worked with a facility that was shipping small calibration check sources to customer sites several times a month. They had been preparing each shipment as a fully labeled Type A package—spec packaging, YELLOW-II labels, full shipping papers, CHEMTREC contract for the emergency phone number. When we reviewed the activity levels, every single source was well within the UN2910 limited quantity limits. By switching to excepted package classification, they cut their per-shipment prep time significantly, dropped the CHEMTREC requirement, and most importantly, their regular FedEx and UPS drivers could accept the packages without the hazmat surcharges. That change saved them real money over the course of a year.

Marking Requirements for Excepted Packages

Although excepted packages skip most labeling and marking requirements, a few still apply under 49 CFR 173.422:

• UN number on the outside: The applicable UN identification number (UN2908, UN2909, UN2910, or UN2911) preceded by “UN”
• “Radioactive” on inner packaging: The word “Radioactive” must appear on the outside of the inner packaging, or if there is no inner packaging, on an internal surface of the package visible when opened
• “RQ” marking: If the material meets the definition of a hazardous substance, the letters “RQ” must also appear on the outside

The marking mistake I see most often is leaving old radioactive labels on packages. This is especially common with empty containers (UN2908) being returned—the shipper marks UN2908 on the outside and adds the “Empty” label but doesn't remove or cover the original YELLOW-II or YELLOW-III labels from the inbound shipment. Carriers see conflicting information and either reject the package or flag it for additional review. Take the extra two minutes to remove or fully cover the old labels.

How to Determine If Your Shipment Qualifies

Follow these steps to determine whether your material can ship as an excepted package:

1. Identify the category: Is this an empty package, a manufactured U/Th article, a standalone material (limited quantity), or a material built into an instrument?
2. Look up your A₁/A₂ values: Find your radionuclide in the table at 49 CFR 173.435
3. Calculate your limit: Using Table 4 of 49 CFR 173.425, apply the correct fraction based on physical state and form
4. Compare activity to limit: Your package activity must be at or below the calculated limit
5. Verify dose rate: Measure the package surface—must be ≤ 0.005 mSv/h (0.5 mrem/h)
6. Check contamination: Confirm external non-fixed contamination is within limits
7. Confirm no fissile material: Unless excepted under 49 CFR 173.453 (or ≤ 15 g U-235 for instruments)

My approach is to start with the activity. If I know the radionuclide and the activity, I can quickly compare it to the excepted limits. For common nuclides like Cs-137, Co-60, or Am-241, I have the A1/A2 values committed to memory and can do the fraction in my head. For anything less common or for mixtures, I use RAMcalc—trying to do a sum-of-fractions calculation manually with scientific notation is where errors creep in. That being said, always verify the dose rate with an actual survey. Activity calculations tell you if you're in the right ballpark, but the dose rate measurement is what confirms qualification.

How RadShip.com Helps

RadShip.com simplifies excepted package determination by:

• RAMcalc – Automatically compares your activity against the excepted package limits in Table 4 of 173.425 and tells you whether your shipment qualifies. It selects the correct UN number based on your material and activity.
• LabelCalc – If your package doesn't qualify as excepted, LabelCalc determines the correct label category and TI for the next classification level.
• Consistent, auditable output that documents your classification decision—useful if a carrier or inspector questions why the package isn't labeled.

Here's the reality: the Table 4 lookup is where most manual errors happen. You need to find the right row based on physical state and form, select the correct column for limited quantity vs. instrument, then multiply a fraction in scientific notation by an A1 or A2 value that's also in scientific notation. One decimal place error and you could misclassify the package. I've reviewed calculations where shippers confused 10⁻³ with 10⁻² and thought their material didn't qualify as excepted when it actually did—or worse, thought it qualified when it didn't. An automated tool eliminates that entire category of error.

Try it free for 7 days.

Common Questions

Can excepted packages be shipped by air?

Yes, but with additional requirements. IATA has its own provisions for excepted packages that align with the IAEA regulations. The basic concept is the same, but air shipments may have additional documentation requirements. Importantly, the domestic dose rate exception for instruments (0.02 mSv/h) does not apply to air transport.

Do I still need a shipping paper for excepted packages?

In most cases, yes. Under 49 CFR 173.421, excepted packages are exempted from shipping paper requirements only if the material is not also a hazardous substance or hazardous waste. If it is (which covers many radionuclides), you still need a shipping paper—though it's significantly simplified compared to a labeled package. When in doubt, prepare the shipping paper.

What if my package is right at the activity limit?

You must be at or below the limit, not above it. If you're borderline, account for measurement uncertainty and any decay corrections. A conservative approach is to apply a small safety margin. If your activity is genuinely at the boundary, the safer path is to ship as a fully labeled package rather than risk exceeding the excepted limit.

Can I ship multiple excepted packages in the same vehicle?

Yes. Since excepted packages don't have a Transport Index, the TI-based vehicle loading limits that apply to labeled packages don't come into play. Each package is evaluated independently against its own excepted limits.

In my experience, over-classification of excepted-eligible material is more common than most people realize. Shippers default to the full labeled package treatment because it feels safer from a compliance perspective—but over-regulating a shipment is itself a misclassification. DOT expects you to classify accurately, not just conservatively. Understanding excepted packages isn't optional knowledge for RAM shippers; it's a core competency that directly affects your shipping costs, carrier options, and compliance posture.

Summary: Your Excepted Package Checklist

Before shipping a package as excepted, verify:

• ☐ Activity is within Table 4 limits of 49 CFR 173.425 for your excepted type
• ☐ Surface dose rate ≤ 0.005 mSv/h (0.5 mrem/h) at any point
• ☐ External non-fixed contamination within 49 CFR 173.443(a) limits
• ☐ No fissile material (unless excepted under 173.453 or ≤ 15 g U-235 for instruments)
• ☐ Package meets general design requirements of 49 CFR 173.410
• ☐ UN number marked on outside of package
• ☐ “Radioactive” marked on inner packaging or visible internal surface
• ☐ Simplified shipping paper prepared (if required)
• ☐ For empty packages (UN2908): old labels removed/covered, “Empty” label applied
• ☐ Package securely closed to prevent leakage during transport

Or use RAMcalc to determine your classification automatically.

Regulatory References

DOT Requirements:

• 49 CFR 173.410 – General design requirements for Class 7 packages
• 49 CFR 173.421 – Excepted packages for limited quantities (UN2910)
• 49 CFR 173.422 – Additional requirements for excepted packages (marking)
• 49 CFR 173.424 – Excepted packages for instruments or articles (UN2911)
• 49 CFR 173.425 – Table of activity limits for excepted packages (Table 4)
• 49 CFR 173.426 – Excepted packages for manufactured uranium/thorium articles (UN2909)
• 49 CFR 173.428 – Empty Class 7 packaging (UN2908)
• 49 CFR 173.435 – Table of A₁ and A₂ values
• 49 CFR 173.443 – Contamination control limits

IATA (Air Transport):

• IATA Dangerous Goods Regulations, Section 10 – Radioactive material provisions including excepted packages