Exemption, exception and other criteria for transport criticality safety

Many strange concepts, requirements and specifications related to criticality safety are present in the Regulations [1]. Some earlier problems have been corrected but, going back to 1961 and the first edition of the Regulations, [11] it seems as many changes have been to the worse. Fissile material was defined correctly as a material that could consist of or contain fissile nuclides. Materials consisting of pure fissile nuclides don’t exist but are important in package designs. 238Pu was included as a fissile nuclide only as an emergency, because there was no alternative, but this caused some people to think that all nuclides supporting criticality are fissile. Neutron interaction between different (non-identical) packages had to be evaluated, making the transport index or allowable number of packages a credible safety control. That is not true anymore. The 15 gram exception limit for fissile nuclides was combined with a transport mode limit, similar to but more restrictive than the current consignment limit. The confinement system was introduced to help with formulation of a single requirement for safety of the containment system but is becoming something very different. Controls before the first use of a packaging have become controls of the first use of a package, supporting multiple shipments of the same package.