{"operation":"document","citation":"10-0109","title":"Mr. Scott A. Pilch — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2010-10-14","effective_on":null,"summary":"10-0109 concerning 173.62.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0109.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0109.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0109","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2010/100109.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation 1200 New Jersey Ave, SE\nWashington, D.C. 20590\nPipeline and Hazardous Materials\nSafety Administration\nOCT 1 4 2010\nMr. Scott A. Pilch\n107 Mesa Drive\nEvanston, WY 82930\nReference No. 10-0109\nDear Mr. Pilch:\nThis responds to your request for clarification of the Hazardous Materials Regulations (HMR; 49\nCFR Parts 171-180) applicable to jet perforating guns. Specifically, you ask the meaning of US 1\n(l)(d)(i) following the § 173.62(c) Table of Packing Methods, which states in part:\nA motor vehicle transporting a (perforating) gun must have specially built racks or carrying\ncases designed and constructed so that the gun is securely held in place during transportation\nand is not subject to damage by contact, one to the other or any other article or material\ncarried in the vehicle;\nYou ask whether this paragraph means that: (1) perforating guns are to be transported and secured in\na manner that will eliminate movement that would allow the perforating guns to contact (strike) other\nguns or articles in the load; or (2) perforating guns are to be transported and secured in a manner that\ndoes not allow them to contact (touch) other guns, i.e; the guns are not allowed to lay side-by-side so\nthat they touch each other.\nUS I (I)(d)(i) means that the guns must be secured in place in specially built racks or carrying cases\nin a manner to prevent the guns from any contact (including touching) with other guns, as well as\nwith other articles or materials, being transported in the vehicle that will cause damage to the\nperforating guns.\nI hope this information is helpful. Please contact this office should you have additional questions.\nSincerely,\nr--7~~-::Y/~\nT. Glenn Foster\nChief, Regulatory Review and Reinvention\nOffice of Hazardous Materials Standards\n\n<<<PAGE 2>>>\n\nM C1n.J:JVG\n4113·h3\nPQc..ic.. Cc..91~&Cepl-,Ons\n107 Mesa Drive\nEvanston, WY 82930 I0\" D,0\"1\n(307) 679-1517\nu.s. DOT\nPHMSA Office of Hazardous Materials Standards\nAttn: PHH-10\nEast Building\n1200 New Jersey Avenue, SE.\nWashington, DC 20590-0001\nSir/Madam:\nI am requesting an interpretation on the following:\n49 CFR 173.63-Table of Packing Methods-US l-(i)\nI(A motor vehicle transporting a (pet/orating) gun must have specially built racks or carrying cases\ndesigned and constructed so that the gun is securely held in place during transportation and ;s not\nsubject to damage by contact, one to the other or any other article or material carried in the vehicle;\"\nSome read this regulation to mean that perforating guns are transported and secured in a manner that\nwill eliminate movement that would allow perforating guns to contact (strike) other guns or articles in\nthe load.\nOthers read this regulation to mean that perforating guns are transported and secured in a manner that\ndoes not allow them to contact (touch) other guns. This is, the guns are not allowed to lay side by side\nso that they touch each other.\nI would appreciate you interpretation on this.\nRegards,\nScott A. Pilch","truncated":false,"body_characters":3011}