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

- **operation:** document
- **citation:** 04-0086
- **title:** Sporting Arms and Ammunition Manufacturers" Institute, Inc. — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2004-06-08
- **effective on:** Not available
- **summary:** 04-0086 response to Sporting Arms and Ammunition Manufacturers" Institute, Inc. concerning 172.202.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-interpretation-04-0086.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-interpretation-04-0086.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-04-0086
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2004/040086.pdf
**body:**

<<<PAGE 1>>>

U.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 2>>>

INFOCNTR
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
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