Sporting Arms and Ammunition Manufacturers" Institute, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department JUN 8 2004 of Transportation 400 Seventh St., S.W. Washington, D.C. 20590 Special Programs Research and Administration Mr. Bob Van Duzer Reference No.: 04-0086 Sporting Arms and Ammunition 1339 Broad Run Road Manufacturers' Institute, Inc. Landenberg, PA 19350 Dear Mr. Van Duzer: This is in response to your email concerning the requirement to indicate the "net explosive mass" when describing a Class 1 material on a shipping paper under § 172.202(a)(5)(i) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You describe a typical package for cartridges, small arms, as having a net mass of 10.66 kg, of which 0.333 kg is the mass of the smokeless powder contained in the cartridges. You ask whether the entry on the shipping paper should be the net mass of the explosive articles (i.e., the cartridges) or the explosive substance (e.g., smokeless powder) contained in the articles. For an explosive that is an article, such as cartridges, small arms, it is our determination that the net mass of the article must be used to satisfy the total quantity requirement in § 172.202(a)(5)(i). As a practical matter, it is easier, and in certain instances necessary, for an offeror to determine and provide the net mass of the article. For example, the net mass of an article must be used to ensure compliance with the per package quantity limitations set forth in Column 9 of the § 172.101 Hazardous Materials Table. See § 172.101(j)(3). For operational purposes, such as for stowage and segregation of large quantities of explosives or determining the quantity of explosives that can be transported on a vessel [see § 176.142(b)], it also may be necessary to obtain the net explosive mass (weight) of the explosive substances contained in articles from other data sources. We have submitted a paper (copy enclosed) to clarify this shipping paper requirement in regard to a similar provision in the United Nations Model Regulations on the Transport of Dangerous Goods and also intend to clarify the HMR in the near future. I trust this satisfies your inquiry. If we can be of further assistance, please contact us. Sincerely, Elmas 7. Magelle Edward T. Mazzullo Director, Office of Hazardous Materials Standards 172:202 (a)s) (1) 040086#

Page 2INFOCNTR Corbin From: To: Sent: Sunday, March 21, 2004 3:07 PM. SHIPITSAFE@aol.com Subject: Cc: INFOCNTR §172.2026)EX0) SHIPITSAFE@aol.com Request for Information Shipping Papers In accordance with Docket: HM-215E (final rule published in the July 31, 04-0086 of Federal Register) it will be mandatory on October 1, 2004 for shippers shipping Class 1 (Explosives) to indicate in the shipping description, on the paper, the net explosive mass. mass"? What is the definition of "net explosive containing We ship cartridges, small arms, UN0012. A typical shipping carton 10.66 cartridges, small arms, has a gross weight of 11.34 kg, a net weight of kg, and a tare weight of . 68 kg. Included in the net weight of 10.66 kg is (10.327 . 333 kg of explosives (smokeless powder). The balance of the net weight How is kg) is composed of non-hazardous materials (metal/plastic components). explosives in the net explosive mass to be reported? Is it the weight of the net the package or the weight of the completed article? As you can see the definition I can explosive weight is minimal compared to the "net quantity" is that finished which appears in the article. The only ICAO Technical nass of Instructions which defines "net quantity" of explosive articles as the the finished article excluding packagings. definition for explosives? Thanks for your assistance. • Does DOT concur with this 3ob Van Duzer 1339 Broad Run Road Sporting Arms and Ammunition Manufacturers" Institute, Inc. Tel: (610)| 'andenberg, PA 19350 Fax (5610) 274-0745) 274-0720 Email: shipitsafe@aol.com#