# Mr. Scott A. Pilch — Hazardous Materials Safety Interpretation

**Citation:** 10-0109  
**Type / status:** guidance / guidance  
**Agency:** Pipeline and Hazardous Materials Safety Administration  
**Effective:** Not stated  
**Published:** 2010-10-14

10-0109 concerning 173.62.

## Document text

<<<PAGE 1>>>

U.S. Department of Transportation 1200 New Jersey Ave, SE
Washington, D.C. 20590
Pipeline and Hazardous Materials
Safety Administration
OCT 1 4 2010
Mr. Scott A. Pilch
107 Mesa Drive
Evanston, WY 82930
Reference No. 10-0109
Dear Mr. Pilch:
This responds to your request for clarification of the Hazardous Materials Regulations (HMR; 49
CFR Parts 171-180) applicable to jet perforating guns. Specifically, you ask the meaning of US 1
(l)(d)(i) following the § 173.62(c) Table of Packing Methods, which states in part:
A motor vehicle transporting a (perforating) gun must have specially built racks or carrying
cases designed and constructed so that the gun is securely held in place during transportation
and is not subject to damage by contact, one to the other or any other article or material
carried in the vehicle;
You ask whether this paragraph means that: (1) perforating guns are to be transported and secured in
a manner that will eliminate movement that would allow the perforating guns to contact (strike) other
guns or articles in the load; or (2) perforating guns are to be transported and secured in a manner that
does not allow them to contact (touch) other guns, i.e; the guns are not allowed to lay side-by-side so
that they touch each other.
US I (I)(d)(i) means that the guns must be secured in place in specially built racks or carrying cases
in a manner to prevent the guns from any contact (including touching) with other guns, as well as
with other articles or materials, being transported in the vehicle that will cause damage to the
perforating guns.
I hope this information is helpful. Please contact this office should you have additional questions.
Sincerely,
r--7~~-::Y/~
T. Glenn Foster
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards

<<<PAGE 2>>>

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107 Mesa Drive
Evanston, WY 82930 I0" D,0"1
(307) 679-1517
u.s. DOT
PHMSA Office of Hazardous Materials Standards
Attn: PHH-10
East Building
1200 New Jersey Avenue, SE.
Washington, DC 20590-0001
Sir/Madam:
I am requesting an interpretation on the following:
49 CFR 173.63-Table of Packing Methods-US l-(i)
I(A motor vehicle transporting a (pet/orating) gun must have specially built racks or carrying cases
designed and constructed so that the gun is securely held in place during transportation and ;s not
subject to damage by contact, one to the other or any other article or material carried in the vehicle;"
Some read this regulation to mean that perforating guns are transported and secured in a manner that
will eliminate movement that would allow perforating guns to contact (strike) other guns or articles in
the load.
Others read this regulation to mean that perforating guns are transported and secured in a manner that
does not allow them to contact (touch) other guns. This is, the guns are not allowed to lay side by side
so that they touch each other.
I would appreciate you interpretation on this.
Regards,
Scott A. Pilch

## Provenance

- Official: Yes
- Source: <https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2010/100109.pdf>
- Source ID: `phmsa`
- SHA-256: `4ca8410fac1bcdbae2814285d728367fab7802fed9988a2266b19cf5756b87d2`
- Retrieved: 2026-08-20T00:59:31.977Z
- Exported: 2026-08-22T12:49:24.168Z
- Document slug: `phmsa-interpretation-10-0109`

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