Department of the Army — Hazardous Materials Safety Interpretation

Page 1U.S. Department 400 Seventh St., S.W. of Transportation Washington, D.C. 20590 Special Programs Research and Administration OCT 3 0 2001 Mr. William R. Frerichs Ref. No: 01-0280 Department of the Army US Army Defense Ammunition Center 1 C Tree Road McAlester, OK 74501-9053 Dear Mr. Frerichs: This is in response to your October 2, 2001 letter requesting clarification of segregation requirements for explosives under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you ask whether a dromedary unit that is attached to the cab of a tractor trailer unit is considered a separate transport vehicle from the trailer. You intend to transport incompatible explosives separated in this manner. The answer is yes. A dromedary unit that is attached to the cab of a tractor trailer unit where incompatible explosives are transported with one group in the dromedary unit and one group on the trailer is acceptable for hazardous materials that may not be transported on the same transport vehicle. I hope this information is helpful. Sincerely, Rehen Hillis, Delmer F. Billings Office of Hazardous Materials Standards Chief, Standards Development 010280#

Page 2LaValle DEPARTMENT OF THE ARMY US ARMY DEFENSE AMMUNITION CENTER $177.848 MCALESTER, OK 74501-9053 1C TREE ROAD ATTENTION OF October 2, 2001. Segregation SMAAC-DE 01-0280 Mr. Edward Mazzullo Office of Hazardous Materials Standards Director 400 7th Street SW Washington, DC 20590 Dear Mr. Mazzullo: attached to the Heavy Expanded Mobility Tactical Truck with Load Handling This office was tasked to design a DROM Box that could be directly - System (HEMTT-LHS) . intends to use the box to store and transport a small amount of fuzes or The Interim Brigade Combat Team (IBCT) in Fort Lewis, WA signal/smoke devices. The box is separate from the demountable HEMTT-LHS flatrack. Enclosed (attachment 1) is a detailed description of the DROM box and the HEMTT-L.HS truck. The IBCT HEMTT-LHS vehicles are loaded at Fort Lewis, WA and travel over public highways to reach the training site in Yakima, WA. The DROM box would allow the IBCT to carry all required training items on the HEMTT-LHS vehicle. This would eliminate the need for additional transportation vehicles to carry the required small amount of fuzes ox signal/smoke devices. concept is in compliance with 49 CFR, section 177.848, Segregation of This office has reviewed the DROM Box concept and concluded that the The incompatible items are on separate transport vehicles. demountable flatrack with cargo is offloaded to the ground and the HETT-LHS The DROM box is stored directly on the HEMTT-LHS and the with DROM box containing the incompatible items drives away. The IBCT HEMTT-LHS is identical to a semi-truck storing incompatible items the fact it can unhitch from the semi-trailer and drive away with the in a dromedary behind the cab. The semi-truck is allowed to do this based on - incompatible items (two cargo carrying bodies). section 177.848, Segregation of Hazardous Materials. We request that your office concur with our interpretation of 49 CFR, By 2 Not Quide Your concurrence or reasona fox non-concuzzence to thia office Point of contact is Mr. Michael Bartosiak, SMAAC-DET, commercial telephone number (918) 420-8083. Sincerely, Mack Gorda - for Associate Director for Engineering William R. Frerit Enclosure#