HITECH — Hazardous Materials Safety Interpretation

Page 1400 Seventh St., S.W. Washington, D.C. 20590 Research and Special Programs Administration FEB 2 O 2001 Ms. Jackie Brian Ref. No. 00-0328 Materials Manager HITECH P.O. Box 3112 East Camden, AR 71711 Dear Ms. Brian: This responds to your November 3, 2000 letter requesting clarification pertaining to the instructions for using the compatibility table for Class 1 explosive materials under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask for a clarification of § 177.848(g)(3)(vi) regarding explosive articles in compatibility group G, being loaded with explosive articles in compatibility groups C, D and E. Your understanding is correct. Section 177.848(g)(3)(vi) permits you to transport explosive articles in compatibility group G with explosive articles in compatibility groups C, D, and E, provided the compatibility group G articles are not fireworks or those requiring special stowage and further provided that no explosive substances are carried on the same vehicle. An explosive substance is a material which meets the definition of an explosive as defined by Subpart C of Part 173 of the HMR, and is designed to produce a practical effect by explosion. An explosive article is a device containing an explosive substance, such as a detonator or a cartridge for weapons. In the examples you provide in your letter, you may load a truck with a combination of Rocket Motors, UN 0186, 1.3C and Ammunition Smoke, UN 0015, 1.2G. However, you may not load a truck with a combination of Ammunition Smoke, UN 0015, 1.2G and Hexolite, UN 0118, 1.1D. I hope this answers your inquiry. Sincerely, John A. Gale Transportation Regulations Specialist Office of Hazardous Materials Standards 000328#

Page 2boothe §171.848 (g) HITECH Compatibility A PRIMEX TECHNOLOGIES COMPANY November 3, 2000 JWB35300 U.S. Department of Transportation Ref. No. 09-0328 Attn.: DHM10 Edward Mazzulo 400 7 Street, SW Washington, D.C. 20590-0001 Subject: DOT Rulé Clarification (177.848) Dear Edward, I am writing this letter to request clarification pertaining to (49 CFR 177.848 (g)) instructions for using compatibility table for Class 1 materials. 177.848 (g) (vi) makes reference to explosive articles from compatibility group G, being loaded with explosive articles from capability group C, D and E, provided no explosive substances are carried on the same vehicle. My interpretation of this is, (A) The definition of an explosive article would be, example Rocket Motors UN0186, 1.3C, Rockets UN0181, 1.1E, Ammunition Smoke UN0015, 1.2G or 0016, 1.3G. (B) The definition of explosive substance would be, example Pentolite UN0151, 1.1D, Hexolite UN0118, 1.1D, Cyclotetramethylenetetranitramine UN0483 or 0484, 1.1D. The following is an example of what I think 49 CFR, 177.848 (g) (vi) allows. It would be allowed by the regulations to load a truck with a combination of Rocket Motors UN0186, 1.3C and with a combination of Ammunition Smoke UN0015, 1.2G and Hexolite UNO118, 1.ID. Ammunition Smoke UN0015, 1.2G. It would not be allowed by the regulations to load a truck I appreciate your time in helping me reach a conclusion to this matter. If you have any question pertaining to this letter, I can be reached phone, fax or e-mail. The numbers and address are on the attached business card. Thank you, JackieBian Jackie Brian Materials Manager JWB/sT P.O. Box 3112, East Camden, AR 71711 • Telephone: (870) 798-4171#