Hazmat Seminars — Hazardous Materials Safety Interpretation

Page 1of Transportation U.S. Depatment 400 Seventh Street, S.W. Washington, D.C. 20590 Pipeline and Administration Hazardous Materiais Safety APR 12 2005 Mr. Paul Shelton Ref No.: 05-0033 Post Office Box 6122 Hazmat Seminars Oak Ridge, Tennessee 37831 Dear Mr. Shelton: This responds to your January 26, 2005 letter requesting clarification of the packaging requirements for explosives contained in § 173.62 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if shippers are free to assuming there is no packaging specified in the approval letter, even when that option differs from the configuration in which classification testing was conducted. The competent authority approval issued by the Associate Administrator for Hazardous Materials Safety is the definitive statement of proper shipping name, identification number, and classification code for new explosives. The approval document may also contain additional stipulations, including packaging requirements. Any packaging information contained in the approval document takes precedence over the requirements contained in the Table of Packing Methods in § 173.62. If the approval does not contain specific packaging requirements, the explosive must be packaged as prescribed in the Table of Packaging Methods found in § 173.62. In these instances, you may utilize any packaging; configuration authorized by the packing instruction for the explosive. I hope this information is helpful. Please contact us if you require additional assistance. Sincerely, John A. Gale Chief, Standards Development Office of Hazardous Materials Standards 173.62 050033#

Page 2HAZMAT SEMINARS OAK RIDGE, TENNESSEE 37831 POST OFFICE BOX 6122. DOT/RSPA/ Supko CERTIFIED MAIL NO. 5768 3240 $173.62 OSFEB -7 PH RETUR V RECEIPT REQUESTED Patkaging of January 26, 2005 05 FEB - 7 Explosives Chief, Interpretations DOT/ESPA / OMMS P.S. De and sent of Transpars Administration 05-0033 400 Seventh Street, SW Washington. DC 20590 Re: 49 CFR 173 Subpart C: Packaging of Explosives I am an instructor in hazardous materials transportation regulations, including the DOT Regulations applicable to the classification, packaging, and transportation of explosives. An issue has arisen in several classes concerning the flexibility provided by the Table of Packing Methods in $173.62. It is clear that the new explosive classification document issued by the Associate and classification code. It is also routine for the Associate Administrator to include Administrator is the definitive statement of proper shipping name, identification number, additiona requirements or limitations in the document, frequently stipulating packaging which much be utilized for commercial transport. Where such stipulations differ from provisions in the Table of Packing Methods in §173.62, it is understood that the classification document takes precedence over the Table. The question concerns those situations in which the new explosive classification document is silent on packaging requirements, and the identification number is used to reference a packing instruction in §173.62. In such situatiors, are shippers free to utilize from the configuration in which classification testing was conducted? any option provided in the referenced packing instruction, even when that option differs Thank you for your assistance. Paul Shelton HAZMAT SEMINARS TELEPHONE: (865) 693-2837 • FAX: (865) 470-4444#