General Dynamics - OTS — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Depanment 400 Seventh St., S.W. Washington, D.C. 20590 Research and Special Programs Administration JUN 17 2004 Mr. John Wells Ref. No. 04-0121 Environmental Specialist General Dynamics - OTS 8820 Route 148 South Marion, IL 62959 Dear Mr. Wells: This responds to your May 5, 2004 letter requesting clarification on §173.56 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding new explosive approvals. Specifically, you ask whether a new explosives approval is required for any of the following revisions/changes to a current explosives approval: (1) part number of an explosive device changes; (2) revisions levels to a drawing; and (3) suffix numbers are added to a part number. Your questions are paraphrased and answered as follows: Q1. Part number of an explosive device changes. If our engineering department changes the part number of our currently approved device, would this require a new DOT approval? There are no changes to the design, components, or energetic materials of this device. A1. A new approval is not required. However, you must submit a request to the Office of Exemptions and Approvals in writing to include the new part number in your current approval. Q2. Revision levels to a drawing. If a part number for a drawing was changed to JW9000 Revision A, would this require a new approval? The revision may be as simple as a change in ink energetic materials of this device. color used to mark the item. In addition, there are no changes to the design, components, or 173.56 040121#

Page 2Q3. Suffix numbers added to a part number. (Due to design change, with no energetic material change). If a minor change to a device, such as number of threads or angle of chamber, and the new part number is now changed, would a new approval be required? There are no changes to the energetic materials or the functionality of this device. A3. See answer A2 above. I hope this answers your inquiry. Sincerely, John A. Gate (Chice of Hazardousy dopenint Office of Hazardous Materials Standards#

Page 3May-04-2004 14:42 From-GENERAL. DYNAMICS +6189939495 T-805 P. 001/001 F-344 GENERAL DYNAMICS Ordnance and Tactical Systems May 5, 2004 Boothe U.S. Department of Transportation Mr. Edward Mazzullo, Director $173.56 Office of Hazardous Materials Standards, DHM-10 400 Seventh Street, S.W. Explosives Washington, DC 20590-0001 202-366-8553 202-366-3012 FAX 04-0121 Subject: Request for Clarification Reference: 49 CFR 173.56 Dear Mr. Mazzullo: General Dynamics, OTS, Marion, is requesting a letter of interpretation. Would any of the following conditions would require a new DOT approval: 1. The part number of an explosive device changes. If we currently had a competent authority approval for theoretical part number JDW-500, and our engineering department changes the part number of this device to theoretical part number 6009854, would this require a new DOT approval? Note thai there are no changes to the design, components, or encrgetic materials of this device. 2. Revision levels to a drawing. If we currently had a competent authority approval for theoretical part number JW9000, and the item is revised to JW9000 Revision A, would this require a new DOT approval? The revision may of been as simple as color change of the ink used to mark the item. Note that there are no changes to the design, components, or energetic materials of this device. 3. Suffix numbers added to a part number due to design change, but no energetic material change. If we currently had a competent authority approval for theoretical part number 6292300, and engineering made a minor change to the device, such as number of threads or angle of chamfer, and the new theoretical part number becomes 6292300-10, would this require a new DOT approval? Note that there are no changes to the energetic materials or the functionality of this device. If the answer to any of the above three questions is no, is it necessary to note on the shipping documents either or both part numbers? Regards. Tora wel Environmental Speciali General Dynamics - OTS Environmental and Regulatory Compliance John Wells, Environmental Specialist 8820 Route 148 South. Marion, IL 62959 Tel 618-993-8511 Fax 618-993-9495#