{"operation":"document","citation":"10-0187","title":"Schlumberger Technology Corporation — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2010-10-27","effective_on":null,"summary":"10-0187 response to Schlumberger Technology Corporation concerning 171.12, 171.22, 171.23.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0187.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0187.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-10-0187","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2010/100187.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration\n1200 New Jersey Ave. SE\nWashington. D.C. 20590\nOCT 27 2010\nMr. Paul Lezak\nSchlumberger Technology Corporation\n200 Gillingham Ln.\nSugar Land, Texas 77478\nRef. No.: 10-0187\nDear Mr. Lezak:\nThis responds to your August 24, 2010 email requesting clarification of the Hazardous Materials\nRegulations (HMR; 49 CFR Parts 171-180). Specifically, you request clarification ofthe marking\nand labeling requirements for materials regulated as explosives that are transported from Canada into\nthe United States.\nAs specified in § 171.12(a), a hazardous material transported from Canada to the United States, from\nthe United States to Canada, or transiting the United States to Canada or a foreign destination may be\noffered for transportation or transported by motor carrier and rail in accordance with the Transport\nCanada TDG Regulations as authorized in § 171.22, provided the requirements in § § 171.22 and\n171.23, as applicable, are met.\nIt should be noted that § 171.23(b)(4) requires that, prior to being transported within the United\nStates, explosive materials must be approved by the Associate Administrator in accordance with\n§ 173.56 and that each package containing a Class 1 (explosive) material must conform to the\nmarking requirements in § 172.320.\nI trust this satisfies your inquiry. Please contact us if we can be of further assistance.\nSincerely,\n/I\nQr\nBen Supko\nActing Chief, Standards Development\nOffice ofHazardous Materials Standards\n\n<<<PAGE 2>>>\n\nW,n-ter\n9 1'13·'66\nDrakeford, Carol\n9 17Z· 10/\nFrom: Betts, Charles (PHMSA) ctr Ktn3\nSent: Wednesday, August 25,20102:24 PM 10- 01 g\nTo: Drakeford, Carolyn (PHMSA)\nSubject: Shipments of explosives from Canada to the US that have different transportation\nclassifications\nCarolyn,\nThanks,\nCharles\nPlease log in this new request for interpretation and assign for proper handling.\nFrom: Paul Lezak [mailto:lezak1@slb.com]\nSent: Tuesday, August 24, 2010 10:01 AM\nTo: Herrera, Jacqueline (PHMSA)\nCc: Singh, Harpreet (PHMSA)\nSubject: Shipments of explosives from canada to the US that have different transportation classifications\nMs. Herrera,\nAs previously discussed, have you received any feedback within your organization regarding the question below?\nThe US DOT and Natural Resources Canada both require explosive products to be classified by their agency before the\nexplosive can be transported in the US or Canada. Since we ship explosives from the US to our field locations in Canada,\nthe explosive must be classified by both the DOT and NRCan. It is common for an explosive product to be assigned one\nclassification in the US and a different classification in Canada. Shipping explosives from the US to Canada is not a major\nproblem because the Canadian authorities allow an explosive shipment from the US to enter Canada marked/labeled\nwith the US classifications until it has been received at the initial destination. After being received at the initial location,\nifthe classification is different, before being reoffered fortransport, the package must be remarked/labeled/shipped\naccording to the Canadian classification.\nHowever, based on what has been communicated to me, currently there is not any provision in 49CFR that would allow\nan explosive shipment from Canada to enter the US marked/labeled per the Canadian classification until it has been\nreceived at the first stop. Can you offer any guidance on this matter? Please advise. If I should address this question to\nanother party within DOT, please provide me the contact information.\nBest regards,\nPaullezak\n(281) 285-5676\n1","truncated":false,"body_characters":3651}