{"operation":"document","citation":"09-0022","title":"NASA Wallops Flight Facility — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2009-04-10","effective_on":null,"summary":"09-0022 response to NASA Wallops Flight Facility concerning 173.56.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0022.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0022.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-09-0022","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/2009/090022.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation Pipeline and Hazardous Materials\nSafety Administration\n1200 New Jersey Ave, S.E.\nWashington, D.C. 20590\nAPR 7 0 2009\nMr. Ernest Cornwell\nNASA Wallops Flight Facility\n32400 Fulton Street, Building M- 16 Room 107\nWallops Island, VA 23337\nRef. No.: 09-0022\nDear Mr. Comwell:\nThis is in response to your letter dated January 23, 2009 requesting clarification of the\nHazardous Material Regulations (HMR; 49 CFR Parts 17 1 - 1 80) applicable to the\nclassification of explosives. In your letter you describe a parachute recovery system that uses\nreefing line cutters classed and approved by the Department of Transportation (DOT) as\n\"Cutters, cable, explosive, 1.4S, UN0070.\" You ask if a reefing line cutter packed in the\nparachute recovery system may also be described as \"Cutters, cable, explosive, UN0070,\n1.4s.-\nThe answer is no. A parachute recovery system with a previously approved reefing line\ncutter installed would be considered a new explosive under 5 173.56 and must be classed by\nDOT. In accordance with $ 173.56, a person requesting approval of a new explosive must\nsubmit to the Associate Administrator a report of the examination and assignment of a\nrecommended shipping description, division, and compatibility group. If the Associate\nAdministrator finds the approval request meets the regulatory criteria, the new explosive will\nbe approved in writing and assigned an EX number. The Office of Hazardous Materials\nApprovals may be reached by telephone at (202) 366-45 1 1.\nI trust this satisfies your inquiry. If we can be of fiirther assistance, please contact us.\nSincerely,\nh\nharles E. Betts\nf, Standards Development\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nPage 1 of 2\nDrakeford, Carolyn cPHMSA>\n- .-\".-\"\".-..-* - - -**- \" * - ---- --* \" -- *- -\nFrom: INFOCNTR <PHMSA>\nSent: To : Tuesday, January 27,2009 2:32 PM\nDra keford, Carolyn <PHMSA>\nSubject: FW: REQUEST FOR CLARIFICATION OF IDENTIFICATION AND PACKAGING OF LIN0070\nCUTTERS, CABLE, EXPLOSIVE, WITH WRITTEN REPLY\nFrom: Cornwell Ernest [mailto:Cornwell~Ernest@nsroc.net]\nSent: Friday, January 23, 2009 2:23 PM\nTo: INFOCNTR <PHMSA>\nCc: Shreves Christopher\nSubject: REQUEST FOR CLARIFICATION OF IDENTIFICATION AND PACKAGING OF UN0070 CUlTERS, CABLE,\nEXPLOSIVE, WITH WRITEN REPLY\nJanuary 23,2009\nCompleted via email by RE3 on 1/26 @ 12:47 pm\nFrom: Mr. Ernest R. Cornwell, Logistics Program Analyst\nNASA Wallops Flight Facility\n32400 Fulton Street, Building M-16 Room 107\nWallops Island, Virginia 23337\nSUBJECT: UN0070 CUTTERS, CABLE, EXPLOSIVE, 1.4S, when packaged in a recovery\nsystem\nNASA Wallops Flight Facility, Wallops Island, Virginia, uses parachute recovery systems for recovery\nof payloads. Normally these systems use reefing line cutters, identified through Department of\nTransportation as the subject LJN ID 0070.\nEach specific cutter is identified with EX number, Competent Authority Approval, as well as MSDS.\nWhen transporting these systems, each of the cognizant authorities understands the shipment of 1.4s in\napproved UN Certified Containers.\nWhen containers are purchased, it is specified that the material to be packaged will be explosive, 1.4\nseries (the containers will also be used to ship explosive 1.4 material in a host of UN identified numbers\n(i.e. UN0323, UN0276, UN0173, etc.).\nThe regulations and requirements for packaging this material identifies the hazardous material to be\npackaged. The assembly is incidental. For Example:\n1. DOMESTIC. U.S. Department of Transportation, provides identification, packaging, and shipment as\nfollows, for UN0070 Cutters, Cable, Explosive, 1.4S, PGII (retrieved online 01/23/2009 from:\nhtt~!edocket._a_c.ces_s~g~o~~.v!.cfr~Z.003!ocf.~~r!4Ucfr.~~73.~62.~1!tm~\n49CFR173.62, SPECIFIC PACKAGING REQUIREMENTS FOR EXPLOSIVES, PI 134: Inner\npackagings (1 1 varieties) including plastic bags. Intermediate packagings not required. The outer\npackaging (1 3 varieties) includes 4C1,4C2 Wooden Packages, and 4G Fiberboard packages.\n\n<<<PAGE 3>>>\n\nPage 2 of 2\n49CFR173.6l(a), MUlED PACKAGING REQUIREMENTS,\n(http.:l!e~.~c~.~t,~~.cesst.gp.~ . go~~!.cf~ ...... Q03!.~.c~.qt~!49.~frl,7~..,6!..,~i~n states \"An explosive may not be packed\nin the same outside packaging with any other material that could, under normal conditions of\ntransportation, adversely affect the explosive or its packaging unless packaged by DOD or DOE in\naccordance with Sec. 173.7(a).\"\nThe parachute recovery system is engineered such that the explosive article is surrounded by sufficient\ncushioning material (parachute fabric), and enclosed in static plastic, to absorb shock and to prevent\nfunction of the device during 4G (Gravity Pressure) Rocket Launches. Therefore, the explosive or its\npacking cannot be adversely affected under normal conditions of transportation.\n2. COMMERCIAL AIR. International Air Transportation Association (IATA), in the 5oth edition\nDangerous Goods Regulations, provides identification, packaging, and shipment as follows, for\nUN0070 Cutters, Cable, Explosive, 1.4s:\nTable 4.2 (pg180)\nUNIID No., Proper shipping name, Class, as listed above.\nPadcargo Packaging Instruction 134, Maximum Net QtyIPkg 25 Kilograms\nCargo Aircraft Only Packaging Instruction 134, Maximum Net QtyiPkg 100 Kilograms\nIn the identification paragraph, 4.1.6.8 Column H, the \"maximum net quantity (weight or volume) of the\narticle or substance allowed in each package for transport on a passenger or cargo aircraft. The weight\nquoted is the net weight.. .\"\nPackaging Instruction 134 (pg 345), subject to State and Operator Variations, provides specific\npackaging instructions for the cutters. Inner Packagings are described, including Plastic or Paper Bags.\nIntermediate Packaging is not required. Combination Packagings are allowed and identified, and, most\nimportantly, Outer packaging is described with specific Certification Identifiers, including: 4C1,4C2\nWooden Packages, and 4G Fiberboard packages.\nQuestion: Does the UN family of UN0070 Cutters, Cable, Explosive, 1.4S, when in packaged and\nprotected in certified parachute recovery systems, can be identified, packaged, marked, labeled,\ndocumented, and transported as UN0070.\nErnest R. Cornwell","truncated":false,"body_characters":6211}