{"operation":"document","citation":"04-0121","title":"General Dynamics - OTS — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2004-06-17","effective_on":null,"summary":"04-0121 response to General Dynamics - OTS concerning 173.56.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0121.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0121.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-04-0121","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2004/040121.pdf","body":"<<<PAGE 1>>>\n\nof Transportation\nU.S. Depanment\n400 Seventh St., S.W.\nWashington, D.C. 20590\nResearch and\nSpecial Programs\nAdministration\nJUN 17 2004\nMr. John Wells\nRef. No. 04-0121\nEnvironmental Specialist\nGeneral Dynamics - OTS\n8820 Route 148 South\nMarion, IL 62959\nDear Mr. Wells:\nThis responds to your May 5, 2004 letter requesting clarification on §173.56 of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) regarding new explosive approvals.\nSpecifically, you ask whether a new explosives approval is required for any of the following\nrevisions/changes to a current explosives approval: (1) part number of an explosive device\nchanges; (2) revisions levels to a drawing; and (3) suffix numbers are added to a part number.\nYour questions are paraphrased and answered as follows:\nQ1. Part number of an explosive device changes. If our engineering department changes the part\nnumber of our currently approved device, would this require a new DOT approval? There are no\nchanges to the design, components, or energetic materials of this device.\nA1. A new approval is not required. However, you must submit a request to the Office of\nExemptions and Approvals in writing to include the new part number in your current approval.\nQ2. Revision levels to a drawing. If a part number for a drawing was changed to JW9000\nRevision A, would this require a new approval? The revision may be as simple as a change in ink\nenergetic materials of this device.\ncolor used to mark the item. In addition, there are no changes to the design, components, or\n173.56\n040121\n\n<<<PAGE 2>>>\n\nQ3. Suffix numbers added to a part number. (Due to design change, with no energetic material\nchange). If a minor change to a device, such as number of threads or angle of chamber, and the\nnew part number is now changed, would a new approval be required? There are no changes to\nthe energetic materials or the functionality of this device.\nA3. See answer A2 above.\nI hope this answers your inquiry.\nSincerely,\nJohn A. Gate\n(Chice of Hazardousy dopenint\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nMay-04-2004\n14:42\nFrom-GENERAL. DYNAMICS\n+6189939495\nT-805\nP. 001/001\nF-344\nGENERAL\nDYNAMICS\nOrdnance and Tactical Systems\nMay 5, 2004\nBoothe\nU.S. Department of Transportation\nMr. Edward Mazzullo, Director\n$173.56\nOffice of Hazardous Materials Standards, DHM-10\n400 Seventh Street, S.W.\nExplosives\nWashington, DC 20590-0001\n202-366-8553\n202-366-3012 FAX\n04-0121\nSubject: Request for Clarification\nReference: 49 CFR 173.56\nDear Mr. Mazzullo:\nGeneral Dynamics, OTS, Marion, is requesting a letter of interpretation.\nWould any of the following conditions would require a new DOT approval:\n1. The part number of an explosive device changes. If we currently had a competent authority\napproval for theoretical part number JDW-500, and our engineering department changes the part\nnumber of this device to theoretical part number 6009854, would this require a new DOT approval?\nNote thai there are no changes to the design, components, or encrgetic materials of this device.\n2. Revision levels to a drawing. If we currently had a competent authority approval for theoretical part\nnumber JW9000, and the item is revised to JW9000 Revision A, would this require a new DOT\napproval? The revision may of been as simple as color change of the ink used to mark the item.\nNote that there are no changes to the design, components, or energetic materials of this device.\n3. Suffix numbers added to a part number due to design change, but no energetic material change. If\nwe currently had a competent authority approval for theoretical part number 6292300, and\nengineering made a minor change to the device, such as number of threads or angle of chamfer, and\nthe new theoretical part number becomes 6292300-10, would this require a new DOT approval?\nNote that there are no changes to the energetic materials or the functionality of this device.\nIf the answer to any of the above three questions is no, is it necessary to note on the shipping documents\neither or both part numbers?\nRegards.\nTora wel\nEnvironmental Speciali\nGeneral Dynamics - OTS\nEnvironmental and Regulatory Compliance\nJohn Wells, Environmental Specialist\n8820 Route 148 South.\nMarion, IL 62959\nTel 618-993-8511\nFax 618-993-9495","truncated":false,"body_characters":4264}