UN2908 and UN2909: Shipping Empty RAM Packages and Manufactured Articles

Why Empty Package Shipping Matters

Every radioactive material package that goes out eventually comes back. Whether it's a Type A container returning from a customer site or a Type B cask headed back to the manufacturer, empty packages still require proper classification and handling. The regulations recognize that these containers pose significantly less risk than loaded ones — but they're not exempt from regulation entirely.

I have seen it where facilities stack up empty containers in a corner because no one is sure how to ship them back. They assume it's either the same process as a loaded shipment or that it requires no paperwork at all. Neither is correct. The excepted package classification gives you a straightforward path — but you have to follow it precisely. Miss a step, and a carrier can reject the package or you can end up with a violation.

Who Needs to Know This

This guide applies to anyone who:

• Returns empty Type A or Type B containers to manufacturers or source suppliers
• Ships depleted uranium shielding, counterweights, or penetrators
• Handles thorium welding electrodes or other thorium-containing articles
• Manages package return logistics for radioactive source shipments
• Works with carriers who transport empty radioactive material packages

UN2908: Empty Radioactive Material Packages

Under 49 CFR 173.428, a package that previously contained Class 7 material qualifies as an excepted empty package when it meets all of the following conditions:

Conditions for UN2908 Shipment

• Emptied as far as practical: All removable radioactive contents must be removed from the package
• External dose rate: Does not exceed 0.005 mSv/h (0.5 mrem/h) at any point on the external surface
• External contamination: Non-fixed contamination on the outer surface does not exceed Table 9 limits
• Internal contamination: Does not exceed 100 times the Table 9 limits
• Package condition: Unimpaired and securely closed — no leakage under normal transport conditions
• Uranium/thorium sheath: Any U or Th in the package structure must be covered with an inactive metal sheath
• Label management: All previous radioactive labels removed, obliterated, or covered; EMPTY label applied
• No fissile material: Unless excepted under 49 CFR 173.453

Contamination Limits (Table 9)

My approach for verifying these limits is to always survey the external surface first with a dose rate meter, then do a wipe test on both the exterior and interior. If you can't reach the interior surfaces for wiping — which is common with source pigs and heavy containers — you can take swipes from accessible internal surfaces and the lid gasket area. That gasket area is where I most often see elevated contamination.

The EMPTY Label Requirement

Under 49 CFR 172.450, empty packages must bear an EMPTY label — a white label with black “EMPTY” text, at least 6 inches (152 mm) per side with letters at least 1 inch (25.4 mm) tall. Before applying this label, you must remove, obliterate, or cover all previous radioactive labels (WHITE-I, YELLOW-II, YELLOW-III).

UN2909: Articles Manufactured from Natural Uranium, Depleted Uranium, or Natural Thorium

Under 49 CFR 173.426, manufactured articles containing only natural uranium, unirradiated depleted uranium, or natural thorium are excepted from specification packaging, labeling, and most marking and shipping paper requirements.

Common UN2909 Articles

• Depleted uranium counterweights: Used in aircraft (Boeing 747 rudders, elevator trim), military vehicles, and forklifts
• DU shielding: Radiation shielding in medical and industrial devices
• DU penetrators: Military munitions components
• Thorium welding electrodes: Thoriated tungsten (2% ThO&sub2;) electrodes used in TIG welding
• Thorium mantles: Legacy gas lantern mantles

Conditions for UN2909 Shipment

• General design: Package meets 49 CFR 173.410 general design requirements
• Protective sheath: Outer surface of the uranium or thorium enclosed in an inactive sheath of metal or other durable material
• External dose rate: Does not exceed 0.005 mSv/h (0.5 mrem/h) at any external surface point
• External contamination: Non-fixed contamination within Table 9 limits
• “Radioactive” marking: Required on the outside of the inner packaging or outer packaging

Keep in mind that the sheath requirement is not just a formality — bare depleted uranium oxidizes over time and creates a fine powder that can become an inhalation and contamination hazard. The sheath keeps the uranium contained and prevents surface degradation during transport.

UN2908 vs UN2909: Key Differences

What Still Applies to Both

Even though UN2908 and UN2909 are excepted from many Class 7 requirements, the following obligations remain:

• UN number marking: “UN2908” or “UN2909” on the outside of each package per 49 CFR 173.422
• Training: All personnel handling these packages must be trained under Part 172, Subpart H
• Incident reporting: Per 49 CFR 171.15 and 171.16 if there is a hazmat incident
• General design: Package must meet 49 CFR 173.410 requirements
• Shipping papers: Required if the material qualifies as a hazardous substance or hazardous waste

What Is Specifically Excepted

For both UN2908 and UN2909, you are not required to provide:

• Specification packaging (no DOT 7A testing needed)
• Radioactive hazard labels (WHITE-I, YELLOW-II, YELLOW-III)
• Transport Index calculation
• Placarding on the vehicle
• Shipping papers (if not a hazardous substance or waste)

That being said, just because these requirements are reduced does not mean you can be careless. I have worked with facilities that assumed an empty package needed no attention at all and let containers sit unchecked for months. By the time they went to ship, one container had a loose lid seal and detectable contamination on the exterior. A quick survey before shipping would have caught it.

Common Shipping Scenarios

Scenario 1: Returning an Empty Source Pig

You received an Ir-192 source in a Type A package for industrial radiography. The source has been removed and returned separately. Now you need to ship the empty container back to the supplier.

• Survey the external surface — confirm dose rate ≤ 0.005 mSv/h
• Wipe test exterior and accessible interior surfaces — confirm within limits
• Remove or cover all YELLOW-II/YELLOW-III labels
• Apply EMPTY label (6” minimum, per 172.450)
• Mark “UN2908” on the outside
• Close securely — ensure no leakage potential
• Ship as excepted package

Scenario 2: Shipping DU Counterweights

A decommissioned aircraft has depleted uranium counterweights that need to go to a licensed disposal facility.

• Confirm each counterweight has an intact protective sheath (metal encasement)
• Survey — confirm dose rate ≤ 0.005 mSv/h at surface
• Wipe test exterior — confirm within Table 9 limits
• Mark “Radioactive” on the inner or outer packaging
• Mark “UN2909” on the outside
• Package in a sturdy container meeting 173.410 general design
• Ship as excepted package

How RadShip.com Helps

RadShip.com simplifies the classification process for empty packages and manufactured articles:

• RAMcalc — Determines whether your shipment qualifies for excepted package classification and identifies the correct UN number
• Generates the proper shipping documentation with the correct proper shipping name and UN number
• Tracks your packages so you know which containers are out and need to come back

Here's the reality: most of the violations I see with empty packages come from simple oversights — forgetting to remove old labels, not surveying before shipping, or using the wrong UN number. Having a system that walks you through the process eliminates those gaps.

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Common Questions

Does an empty package still need specification packaging?

No. That is one of the key benefits of the excepted package classification. The package does not need to meet its original Type A or Type B performance standards for the return trip. It only needs to meet the general design requirements of 49 CFR 173.410.

What if the empty package exceeds the contamination limits?

It cannot ship as UN2908. If contamination exceeds the limits, you have two options: decontaminate the package until it meets the limits, or ship it as a loaded package with the appropriate labels, shipping papers, and UN number for the residual contents.

Can UN2908 packages be shipped by air?

Yes. Excepted packages, including empty packages, can be transported by air. However, air carriers may have additional requirements beyond DOT regulations. Always check with your specific carrier.

What about thorium welding electrodes — UN2909 or something else?

UN2909. Thoriated tungsten electrodes contain natural thorium and qualify as manufactured articles under 49 CFR 173.426. In my experience, many welding supply companies ship these routinely without issues — but they do need the UN2909 marking and proper packaging.

Summary: Your Empty Package Shipping Checklist

Before shipping a UN2908 empty package:

• ☐ Package emptied of radioactive contents as far as practical
• ☐ External dose rate surveyed — ≤ 0.005 mSv/h (0.5 mrem/h)
• ☐ External wipe test — within Table 9 limits
• ☐ Internal contamination verified — within 100x Table 9 limits
• ☐ Package securely closed and in unimpaired condition
• ☐ All previous radioactive labels removed or covered
• ☐ EMPTY label applied (6” per side, 1” letters)
• ☐ “UN2908” marked on outside of package
• ☐ No fissile material (unless excepted under 173.453)

Before shipping a UN2909 manufactured article:

• ☐ Article made from natural U, depleted U, or natural Th — unirradiated
• ☐ Uranium/thorium enclosed in inactive metal or durable sheath
• ☐ External dose rate ≤ 0.005 mSv/h (0.5 mrem/h)
• ☐ External contamination within Table 9 limits
• ☐ “Radioactive” marked on inner or outer packaging
• ☐ “UN2909” marked on outside of package
• ☐ Package meets 173.410 general design requirements

Regulatory References

DOT Requirements:

• 49 CFR 173.428 — Empty Class 7 materials packaging
• 49 CFR 173.426 — Articles manufactured from natural/depleted U or natural Th
• 49 CFR 173.443 — Contamination control (Table 9)
• 49 CFR 173.422 — Additional requirements for excepted packages
• 49 CFR 173.410 — General design requirements
• 49 CFR 172.450 — EMPTY label specification