Exclusive Use Shipments: What It Means and What It Requires

Why Exclusive Use Matters

Most Class 7 packages ride in mixed freight, cross-docked at terminals and handled by people who will never know what a Transport Index is. The regulations make that safe by capping what any single package can emit — under 49 CFR 173.441(a), no more than 2 mSv/h (200 mrem/h) at the package surface and a TI of no more than 10.

Exclusive use is the regulatory answer for shipments that cannot meet those caps. Instead of limiting the package, the rule limits everything around it: one consignor, one conveyance, controlled loading, a briefed carrier, and radiation limits measured on the vehicle rather than just the box. You trade administrative control for dose-rate headroom.

Here is the misunderstanding I run into constantly: people hear “exclusive use” and think it is a pricing tier. I have had shippers tell me they “bought exclusive use” from their carrier, and what they actually bought was dedicated freight service with none of the regulatory controls: no written instructions, no shipping paper statement, nobody controlling the loading. That is not an exclusive use shipment — it is an expensive truck carrying a non-compliant package.

Who Needs to Know This

This applies to anyone who:

• Ships packages above 200 mrem/h at the surface or TI 10 — irradiator sources, large industrial gauges, high-activity waste
• Ships LSA material or SCO — especially unpackaged or in bulk, where exclusive use is required or elected for packaging relief
• Consolidates many packages on one conveyance and needs to get past the TI-sum limit
• Prepares shipping papers for any of the above

What Does “Exclusive Use” Actually Mean?

The definition in 49 CFR 173.403 has three working parts:

1. Sole use: sole use by a single consignor of a conveyance. Your material is the only freight, and you are the only shipper.
2. Controlled handling: all initial, intermediate, and final loading and unloading carried out in accordance with the direction of the consignor or consignee, performed by personnel with radiological training and resources appropriate for safe handling of the consignment.
3. Written instructions: the consignor must give the initial carrier specific written instructions for maintaining exclusive use shipment controls — including the vehicle survey requirement of 173.443(c) where applicable — included with the shipping paper information.

Notice what the definition does not say: nothing about price, expedited service, or the carrier's marketing term for a dedicated trailer. Sole use of the vehicle is necessary but nowhere near sufficient — the controls are what make it exclusive use.

When Is Exclusive Use Mandatory?

There are two paths into exclusive use — radiation levels and material type — plus an optional third where you elect it for the relief it buys.

Path 1: The Package Exceeds the Normal Limits (173.441(b))

Under 173.441(a), a package in ordinary transport may not exceed 2 mSv/h (200 mrem/h) at any point on its external surface, and its TI may not exceed 10. A package exceeding either limit must be transported by exclusive use shipment — that is the word the regulation uses. Your survey readings are not just label inputs; they decide the entire transport arrangement.

Path 2: Unpackaged LSA-I and SCO-I (173.427(c))

LSA-I material and SCO-I may be transported unpackaged, but under 173.427(c)(2) each conveyance must be under exclusive use — with one narrow exception for SCO-I whose surface contamination does not exceed 4.0 Bq/cm² for beta, gamma, and low toxicity alpha emitters, and 0.4 Bq/cm² for all other alpha emitters. If you are hauling contaminated pipe or soil loose in a conveyance, plan on exclusive use.

Path 3: You Choose It for the Relief

Even when nothing forces it, consigning LSA material and SCO as exclusive use unlocks packaging and marking relief under 173.427. More on that below.

What Exclusive Use Unlocks: The 173.441(b) Limits

Under exclusive use, the radiation limits shift from the package to the vehicle. 173.441(b) sets four limits that all apply during transportation:

Read that first row again, because it is the one people get wrong. The 1,000 mrem/h surface allowance is not automatic with exclusive use — it requires a closed transport vehicle, a secured package, and a door-to-door run with no handling in between. Put the same package on a flat-bed and your surface limit is still 200 mrem/h. I have watched shippers plan an open-trailer move around the 1,000 number and have to re-plan the whole shipment when someone finally read 173.441(b)(1) all the way through.

Exclusive use also lifts the conveyance TI ceiling. A non-exclusive use shipment (other than cargo-aircraft-only or seagoing vessel) may not exceed a TI sum of 50 per conveyance (173.441(d)(1)); under exclusive use there is no limit on the sum, provided the vehicle limits in (b)(2)–(b)(4) and the written-instruction requirement in (c) are met (173.441(d)(2)). That is what makes big multi-package consolidations possible on a single truck.

One practical note from the survey side: the (b)(2)–(b)(4) numbers are measured on and around the vehicle, not the package. The readings that matter are taken after the load is secured — at the trailer skin, at 2 meters out, and in the cab. Build that into your loading procedure, because once the driver leaves, nobody is taking those measurements again.

What Exclusive Use Requires of You

1. Specific Written Instructions to the Carrier

This is the obligation that gets missed most often. Under 173.441(c), the offeror shall provide the carrier specific written instructions for maintenance of the exclusive use shipment controls, included with the shipping paper information. The regulation even gives the performance standard: followed correctly, the instructions must cause the carrier to avoid actions that would unnecessarily delay delivery or increase radiation exposures to transport workers or the public.

Good instructions cover: do not open the vehicle en route, do not break the load down or transfer it to another conveyance, who to call if the vehicle is delayed or involved in an incident, and what surveys are required before the conveyance returns to general service. When I hand a driver the paperwork on an exclusive use move, I do not just clip the instructions to the BOL — I walk him through them at the dock. Most drivers have never seen an exclusive use load, and two minutes at pickup prevents the well-intentioned terminal transfer that would blow up the whole arrangement.

2. The Shipping Paper Statement

Under 49 CFR 172.203(d)(9), a shipment required to be consigned as exclusive use must carry an indication of that on the shipping paper — either with each description, or, if every description on the paper is consigned as exclusive use, the statement “Exclusive Use Shipment” entered once in a clearly visible location.

The most common paperwork gap I see is a shipment genuinely being run as exclusive use — sole truck, consignor loading, the works — with a shipping paper that never says so. The reverse also happens: a BOL stamped “Exclusive Use Shipment” with no written instructions attached. Either way, the inspector sees half an exclusive use shipment, and half does not count.

3. Control of Loading and Unloading

All initial, intermediate, and final loading and unloading must happen in accordance with the direction of the consignor or consignee, performed by personnel with radiological training and appropriate resources (173.403). For LSA and SCO consigned as exclusive use, 173.427(a)(6) is even more concrete: loaded by the consignor, unloaded by the consignee, from the conveyance in which originally loaded. No terminal break-bulk, no cross-docking, no forklift driver at a hub consolidating your freight with someone else's. And if you are using the 1,000 mrem/h surface allowance, 173.441(b)(1)(iii) removes the option entirely: no loading or unloading operations between the beginning and end of transportation, period.

4. The After-Trip Obligations

Exclusive use follows the vehicle home. Under 173.443(b), exclusive use shipments by rail or highway get an allowance for non-fixed contamination up to ten times the normal package limits during transport — and because of that allowance, 173.443(c) requires the conveyance to be surveyed after each exclusive use transport before it returns to service. The written instructions must cover this survey where it applies. It is the part nobody remembers, because it happens after the freight is delivered — put it in the instructions and put a name next to it.

Exclusive Use and LSA/SCO: Where It Pays Its Way

For most shippers, the place exclusive use shows up first is not a screaming-hot source — it is LSA material and SCO. Under 49 CFR 173.427, consigning these as exclusive use buys real packaging relief:

• Lower industrial package grades (Table 6): LSA-I liquids drop from IP-2 to IP-1, and LSA-II liquids/gases and LSA-III from IP-3 to IP-2, when the shipment is exclusive use.
• Strong-tight packaging (173.427(b)(4)): for domestic exclusive use shipments under an A₂ quantity, packaging meeting the general design requirements of 173.410 is enough.
• Marking and labeling relief (173.427(a)(6)(vi)): for domestic transport, material under an A₂ quantity is excepted from most marking and labeling, provided each package is stenciled or marked “RADIOACTIVE—LSA” or “RADIOACTIVE—SCO” as appropriate (subsidiary hazard labels still apply, and hazardous substances still need “RQ”).
• Unpackaged transport (173.427(c)): LSA-I and SCO-I can move unpackaged at all — but the conveyance must be exclusive use (with the narrow SCO-I contamination exception), with no escape of contents or loss of shielding under routine conditions.

The obligations come along for the ride: consignor loads, consignee unloads from the original conveyance, no loose radioactive material, bracing against load shift, written instructions with the shipping paper, and placarding per subpart F of part 172 (173.427(a)(6)). Aircraft transport in the relieved packagings is prohibited (173.427(a)(6)(vii)).

My take on the trade: for waste streams and decommissioning freight, exclusive use is almost always worth it. You were chartering the whole trailer anyway, so sole use costs nothing — and the packaging relief compounds across an entire campaign. The compliance work is a checklist, not an engineering problem. Just respect the checklist.

Common Failure Modes

• Buying the truck, skipping the controls. A dedicated trailer without the instructions, the statement, and directed loading is not exclusive use.
• Instructions never reach the driver. 173.441(c) says included with the shipping paper information, not available upon request.
• The 1,000 mrem/h allowance on an open conveyance. Closed vehicle, fixed package, no en-route handling — all three, or the surface limit is still 200 mrem/h.
• Missing the “Exclusive Use Shipment” entry. The operation is compliant; the paper is silent. 172.203(d)(9) makes the statement itself a requirement.
• Surveying the package, not the vehicle. The (b)(2)–(b)(4) limits are conveyance measurements taken with the load in place — and the 173.443(c) post-trip survey still waits at the other end.
• Intermediate handling by a helpful terminal. A hub that cross-docks the load breaks the arrangement. This is exactly what the driver walkthrough is for.

How RadShip.com Helps

RadShip.com takes the guesswork out of the exclusive use decision:

• LabelCalc takes your survey readings and flags when a package crosses the exclusive use threshold — surface over 200 mrem/h or TI over 10 — so the transport arrangement decision happens with the label decision, not at the dock.
• The BOL generator includes the “Exclusive Use Shipment” statement when the shipment requires it, so the 172.203(d)(9) entry is never the thing an inspector finds missing.
• RAMcalc classifies the material behind it all — LSA/SCO determinations included — so the exclusive use question starts from a correct classification.

Exclusive use is a three-part obligation, and humans reliably remember two of the three. Making the shipping paper statement automatic means the surviving failure mode is the one you can fix with a conversation at the dock.

Try it free for 7 days. New to Class 7 generally? Start with How to Ship Class 7 Radioactive Material.

Common Questions

What does “exclusive use” mean in radioactive material shipping?

Sole use of a conveyance by a single consignor, with controlled handling. Under 49 CFR 173.403, all loading and unloading happens under the direction of the consignor or consignee, by radiologically trained personnel, and the consignor gives the initial carrier specific written instructions for maintaining the controls.

When is an exclusive use shipment required?

When the package exceeds the normal transport limits. Over 2 mSv/h (200 mrem/h) at the surface or a TI over 10 means exclusive use is mandatory (173.441(b)). Unpackaged LSA-I and SCO-I also generally require it (173.427(c)). Shippers may also elect it voluntarily for the LSA/SCO packaging relief.

What is the maximum radiation level under exclusive use?

10 mSv/h (1,000 mrem/h) at the package surface — with conditions. The elevated limit applies only in a closed transport vehicle with the package secured and no loading or unloading en route. The vehicle is limited to 2 mSv/h (200 mrem/h) on its outer surfaces, 0.1 mSv/h (10 mrem/h) at 2 meters, and 0.02 mSv/h (2 mrem/h) in any normally occupied space (173.441(b)).

Do I really need written instructions to the carrier?

Yes — specific, written, and included with the shipping paper information. 173.441(c) requires them for every shipment using the exclusive use dose-rate provisions, and 173.427(a)(6)(iv) imposes the same requirement for LSA/SCO exclusive use consignments.

Is exclusive use the same as paying for a dedicated truck?

No. Carriers sell “exclusive use” freight service, and you will usually need something like it to satisfy sole use — but the regulatory arrangement is the controls: written instructions, the shipping paper statement, directed loading, and the vehicle-level radiation limits. The service level is how you buy the truck; the regulation is what you do with it.

Does exclusive use remove the Transport Index limits?

It removes the conveyance sum limit, not the concept. Non-exclusive use conveyances are capped at a TI sum of 50; under exclusive use there is no limit on the sum, provided the vehicle limits and written-instruction requirements are met (173.441(d)). Each package still carries its measured TI on its label and shipping paper.

Summary: Your Exclusive Use Checklist

Before tendering an exclusive use shipment, confirm:

• ☐ Trigger identified: surface > 200 mrem/h, TI > 10, unpackaged LSA-I/SCO-I, or elected for LSA/SCO relief
• ☐ Sole use of the conveyance — single consignor, no co-loaded freight
• ☐ If using the 1,000 mrem/h allowance: closed vehicle, package secured, no en-route loading/unloading
• ☐ Vehicle surveyed after loading: surfaces ≤ 200 mrem/h, 2 m ≤ 10 mrem/h, occupied spaces ≤ 2 mrem/h
• ☐ Written instructions with the shipping paper information — and walked through with the driver
• ☐ “Exclusive Use Shipment” indication on the shipping paper (172.203(d)(9))
• ☐ Loading by consignor, unloading by consignee from the original conveyance; load braced; no loose material (LSA/SCO)
• ☐ Placards per subpart F of part 172 where required
• ☐ Post-trip conveyance survey assigned by name where 173.443(c) applies

Regulatory References

DOT Requirements:

• 49 CFR 173.403 – Definition of “exclusive use”
• 49 CFR 173.441 – Radiation level limitations and exclusive use provisions
• 49 CFR 173.427 – Transport requirements for LSA material and SCO, including exclusive use conditions and Table 6
• 49 CFR 172.203(d) – Additional shipping paper entries for Class 7, including the exclusive use statement
• 49 CFR 173.443 – Contamination control, including the exclusive use allowance and post-trip vehicle survey

Related RadShip Guides:

• How to Ship Class 7 Radioactive Material – the full process, start to finish
• Transport Index Explained – the measurement that triggers exclusive use
• UN2912 & UN2913: LSA and SCO – where exclusive use pays for itself
• Shipping Paper Requirements – every required entry, including 172.203(d)