Mr. Scott A. Pilch — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation 1200 New Jersey Ave, SE Washington, D.C. 20590 Pipeline and Hazardous Materials Safety Administration OCT 1 4 2010 Mr. Scott A. Pilch 107 Mesa Drive Evanston, WY 82930 Reference No. 10-0109 Dear Mr. Pilch: This responds to your request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to jet perforating guns. Specifically, you ask the meaning of US 1 (l)(d)(i) following the § 173.62(c) Table of Packing Methods, which states in part: A motor vehicle transporting a (perforating) gun must have specially built racks or carrying cases designed and constructed so that the gun is securely held in place during transportation and is not subject to damage by contact, one to the other or any other article or material carried in the vehicle; You ask whether this paragraph means that: (1) perforating guns are to be transported and secured in a manner that will eliminate movement that would allow the perforating guns to contact (strike) other guns or articles in the load; or (2) perforating guns are to be transported and secured in a manner that does not allow them to contact (touch) other guns, i.e; the guns are not allowed to lay side-by-side so that they touch each other. US I (I)(d)(i) means that the guns must be secured in place in specially built racks or carrying cases in a manner to prevent the guns from any contact (including touching) with other guns, as well as with other articles or materials, being transported in the vehicle that will cause damage to the perforating guns. I hope this information is helpful. Please contact this office should you have additional questions. Sincerely, r--7~~-::Y/~ T. Glenn Foster Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#

Page 2M C1n.J:JVG 4113·h3 PQc..ic.. Cc..91~&Cepl-,Ons 107 Mesa Drive Evanston, WY 82930 I0" D,0"1 (307) 679-1517 u.s. DOT PHMSA Office of Hazardous Materials Standards Attn: PHH-10 East Building 1200 New Jersey Avenue, SE. Washington, DC 20590-0001 Sir/Madam: I am requesting an interpretation on the following: 49 CFR 173.63-Table of Packing Methods-US l-(i) I(A motor vehicle transporting a (pet/orating) gun must have specially built racks or carrying cases designed and constructed so that the gun is securely held in place during transportation and ;s not subject to damage by contact, one to the other or any other article or material carried in the vehicle;" Some read this regulation to mean that perforating guns are transported and secured in a manner that will eliminate movement that would allow perforating guns to contact (strike) other guns or articles in the load. Others read this regulation to mean that perforating guns are transported and secured in a manner that does not allow them to contact (touch) other guns. This is, the guns are not allowed to lay side by side so that they touch each other. I would appreciate you interpretation on this. Regards, Scott A. Pilch#