{"operation":"document","citation":"01-0092","title":"Alliant Aerospace Company — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2001-06-28","effective_on":null,"summary":"01-0092 response to Alliant Aerospace Company concerning 173.62.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0092.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0092.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-01-0092","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2001/010092.pdf","body":"<<<PAGE 1>>>\n\nS. Departmel\nResearch and\nTransportatio\n400 Seventh St., S.W.\nWashington, D.C. 20590\nsecial Progran\nministratic\nJUN 2 8 2001\nMr. John D. Morgan\nTraffic Coordinator\nReference No.: 01-0092\nP. O. Box 98\nAlliant Aerospace Company\nMagna, UT 84044-0098\nDear Mr. Morgan:\nThis is in response to your April 12 letter requesting clarification of the marking and labeling\nrequirements for shipments of large and robust rocket motors, Division 1.1C or 1.3C, under\nPacking Instruction 130 of § 173.62(c) of the Hazardous Materials Regulations (HMR; 49 CFR\nParts 171-180). You stated that these articles are transported unpackaged, affixed to cradles\nsecured on a flatbed or packaged in handling devices loaded in van trailers.\nThe marking and labeling requirements for these large and robust rockets depend on whether\nthey are construed to be bulk or non-bulk packagings. Section 173.62(a) states that only non-\nbulk packagings are authorized under paragraph (c). Accordingly, § 172.301 states that a non-\nbulk packaging containing a hazardous material shall be marked with the proper shipping name\nand the identification number. Additionally, § 172.320 prescribes that a package containing\nClass 1 materials shall be marked with the EX-number. Under § 172.400, the packages would\nbe labeled unless otherwise excepted; for example, by § 172.400(a)(5) or § 172.400a(a)(2).\nThe markings and labels must be placed directly on the article, i.e. the rocket motor, on a tag or\naffixed by other suitable means.\nI trust this information is helpful.\nSincerely,\nHottez. mitchell\nHattie L. Mitchell\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n010092\n173.62\n\n<<<PAGE 2>>>\n\nSent By: Alliant Aerospace 'Traffic Dept ; 801 251 2091;\nАpr-12-01 12:10;\nPage 6/6\nCarbin\nATK\n8173.62 (130)\nALLIANT TECHSYSTEMS\nLabel ingel Markin\n01-0097\nAlliant Aerospace Company\nMagna, UT 84044-0098\nFax (801) 251 6409\n400 y' South West\nU.S. DOT/RISPA (DHM10)\nWashington, D.C. 20590-0001\nAttention: Edward T. Mazzullo\nDirector of Hazardous Material Standards\nMr. Mazzullo,\nYour support is needed in giving us direction in handling large rocket motors loaded with 1.1C and 1.3C\nDOT Exemption 3415. The DOT has since terminated the exemption and is now using the 49 CFR\nexplosives. Alliant Aerospace previously hauled these large robust motors on flat bed trailers using a\nmarkings and labeling should be performed with regards to shipments of these large motors? The motors\n173.62 note 130 for these shipments. The trouble that we are having with these shipments is what\nequipment. We have had three different Interpretations by three different sources within the DOT on ways\nwe are now shipping are either hauled on flat bed trailers or in enclosed vans with their support\n(unpackaged), therefore, just placard the shipment, no other marking or labeling is necessary. The\nwe should perform our marking and labeling. The first verbal Instruction we received: It Is not packaged\n0188. The third set of Instructions we have received: placard, mark the UN0280 or UN0186, proper\nsecond instruction: placard the shipment 1,1G or 1.3C, mark the shipment with the UN Marking 0280 or\nMr. Mazzullo, we want to comply with the correct requirements. We are seeking your direction when we\nshipping name and the EX-number.\nare shipping large robust motors that are elther shipped on flat bed trailers securely cradled to prevent\nfrom movement. We need your direction as to what we should do when it comes to the requirements of\nmovement during transport or in enclosed vans with the necessary support equipment to secure them\nmarking and labeling. Please see the attached letters and e-mail that I have received with regards to the\npackaging note 130.\nYour direction in this matter will be very much appreciated\nSincerely,\nJohn D. Morgan\nTraffic Coordinator\nJm042001","truncated":false,"body_characters":3853}