Alliant Aerospace Company — Hazardous Materials Safety Interpretation

Page 1S. Departmel Research and Transportatio 400 Seventh St., S.W. Washington, D.C. 20590 secial Progran ministratic JUN 2 8 2001 Mr. John D. Morgan Traffic Coordinator Reference No.: 01-0092 P. O. Box 98 Alliant Aerospace Company Magna, UT 84044-0098 Dear Mr. Morgan: This is in response to your April 12 letter requesting clarification of the marking and labeling requirements for shipments of large and robust rocket motors, Division 1.1C or 1.3C, under Packing Instruction 130 of § 173.62(c) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You stated that these articles are transported unpackaged, affixed to cradles secured on a flatbed or packaged in handling devices loaded in van trailers. The marking and labeling requirements for these large and robust rockets depend on whether they are construed to be bulk or non-bulk packagings. Section 173.62(a) states that only non- bulk packagings are authorized under paragraph (c). Accordingly, § 172.301 states that a non- bulk packaging containing a hazardous material shall be marked with the proper shipping name and the identification number. Additionally, § 172.320 prescribes that a package containing Class 1 materials shall be marked with the EX-number. Under § 172.400, the packages would be labeled unless otherwise excepted; for example, by § 172.400(a)(5) or § 172.400a(a)(2). The markings and labels must be placed directly on the article, i.e. the rocket motor, on a tag or affixed by other suitable means. I trust this information is helpful. Sincerely, Hottez. mitchell Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards 010092 173.62#

Page 2Sent By: Alliant Aerospace 'Traffic Dept ; 801 251 2091; Аpr-12-01 12:10; Page 6/6 Carbin ATK 8173.62 (130) ALLIANT TECHSYSTEMS Label ingel Markin 01-0097 Alliant Aerospace Company Magna, UT 84044-0098 Fax (801) 251 6409 400 y' South West U.S. DOT/RISPA (DHM10) Washington, D.C. 20590-0001 Attention: Edward T. Mazzullo Director of Hazardous Material Standards Mr. Mazzullo, Your support is needed in giving us direction in handling large rocket motors loaded with 1.1C and 1.3C DOT Exemption 3415. The DOT has since terminated the exemption and is now using the 49 CFR explosives. Alliant Aerospace previously hauled these large robust motors on flat bed trailers using a markings and labeling should be performed with regards to shipments of these large motors? The motors 173.62 note 130 for these shipments. The trouble that we are having with these shipments is what equipment. We have had three different Interpretations by three different sources within the DOT on ways we are now shipping are either hauled on flat bed trailers or in enclosed vans with their support (unpackaged), therefore, just placard the shipment, no other marking or labeling is necessary. The we should perform our marking and labeling. The first verbal Instruction we received: It Is not packaged 0188. The third set of Instructions we have received: placard, mark the UN0280 or UN0186, proper second instruction: placard the shipment 1,1G or 1.3C, mark the shipment with the UN Marking 0280 or Mr. Mazzullo, we want to comply with the correct requirements. We are seeking your direction when we shipping name and the EX-number. are shipping large robust motors that are elther shipped on flat bed trailers securely cradled to prevent from movement. We need your direction as to what we should do when it comes to the requirements of movement during transport or in enclosed vans with the necessary support equipment to secure them marking and labeling. Please see the attached letters and e-mail that I have received with regards to the packaging note 130. Your direction in this matter will be very much appreciated Sincerely, John D. Morgan Traffic Coordinator Jm042001#