# Military Surface Deployment and Distribution Command — Hazardous Materials Safety Interpretation

- **operation:** document
- **citation:** 11-0031
- **title:** Military Surface Deployment and Distribution Command — Hazardous Materials Safety Interpretation
- **source type:** guidance
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** guidance
- **official:** true
- **published on:** 2011-02-17
- **effective on:** Not available
- **summary:** 11-0031 response to Military Surface Deployment and Distribution Command concerning 173.62.
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- **app url:** https://regulus.evalyn.ai/document/phmsa-interpretation-11-0031
- **source url:** https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretations/2011/110031.pdf
**body:**

<<<PAGE 1>>>

U.S. Department of Transportation 1200 New Jersey Ave. SE
Washington. D.C. 20590
Pipeline and Hazardous Materials
Safety Administration
FEB 172011
Mr. Joseph P. Dugan
Occupational Safety and Health Specialist
Military Surface Deployment and Distribution Command
Attn: AMSSD-SA
Room 3133, Work Station 3G04i5
One Soldier Way, Building 1900W
Scott Air Force Base, IL 62225
Reference No. 11-0031
Dear Mr. Dugan:
This is in response to your February 7, 2011 e-mail to this agency's Hazardous Materials
Information Center concerning Packing Method 130 under § 173.62(c)(5) of the Hazardous
Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if United Nations
(UN) standard packagings 4B (aluminum box) and 4C2 (natural wood box with sift-proof walls)
were removed in error when this requirement was revised in a final rule published in the Federal
Register on February 2, 2010 [75 FR 5376] under Docket No. PHMSA-2006-25736 (HM-231).
The answer is yes. While revising Packing Method 130 to add UN standard Large Packagings,
the "UN 4B" and "UN 4C2" boxes were inadvertently removed from this section. We will
correct this error in a future rulemaking. This letter is to inform you that continued use of UN
4B and UN 4C2 boxes under § 173.62(c)(5), Packing Method 130, remains authorized.
I hope this satisfies your request.
Sincerely,
)OJ~~
irectol',
S dards and Rulemaking Division

<<<PAGE 2>>>

Drakeford, Carol
From: INFOCNTR (PHMSA) 11- b031
Sent: Monday, February 07,2011 4: 18 PM
To: Drakeford, Carolyn (PHMSA)
Cc: Edmonson, Eileen (PHMSA); Lucas, Adam CTR (PHMSA)
Subject: FW: Request guidance (UNCLASSIFIED)
Attachments: Packaging Instruction 173.62, number 130 (3.99 KB); 49CFR 2009 PI 130.pdf; FedReg
02-02-2010 PI 130.pdf
Importance: High
Hi Carolyn,
We received the following letter of interpretation request at the Info Center. Eileen
Edmonson has begun researching this issue. The Info Center call referenced in the request was
the 2/3/11 conversation between Information Specialist Adam Lucas and caller Janice Hopkins.
Thanks,
Victoria
Victoria Lehman
Hazmat Information Center (HMIC)
Pipeline &Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE, E21-119
Washington, D.C. 20590 http://phmsa.dot.gov/hazmat/info-center
(202) 366-1035
-----Original Message----From:
Dugan, Joseph P Mr CIV USA SDDC [mailto:joseph.dugan@us.army.mill
Sent: Monday, February 07, 2011 2:21 PM
To: INFOCNTR (PHMSA)
Cc: Edmonson, Eileen (PHMSA); Dugan, Joseph P Mr CIV USA SDDC
Subject: Request guidance (UNCLASSIFIED)
Importance: High
Classification: UNCLASSIFIED
Caveats: FOUO
Standards Division,
We have a problem regarding 49 CFR 173.62, Packaging Instruction 130 in the
2009 version of the HMR the following packagings were authorized: 4B and
4C2 (see attachment 1). Later a Final Rule HM231 was published in the Federal Register on
02-02-2010 with an effective date of 10-01-2010, Packaging Instruction 130 was modified, both
authorized packagings 4B and
4C2 were omitted. (see attachment 2)
DOD is a large shipper of explosive materials which use both formerly approved
configurations. Could you please clarify were the 2 packagings removed by design or through
a publishing error?
I have attached a message from one of the DOD Components asking for the guidance (attachment
3), as you can see the HOTLINE did provide a verbal response but I must send out guidance to
the DOD shipping community and require substantive proof that the information we distribute
is verifiable.
1

<<<PAGE 3>>>

Please respond as quickly as possible because at this very moment there are a significant
amount of weapon systems being held pending resolution of this problem.
Thank you.
Joseph P. Dugan
Occupational Safety & Health Specialist Military Surface Deployment and Distribution Command
Attn: AMSSD-SA
Room 3133, Work Station 3G04i5
One Soldier Way, Building 1900W
Scott AFB, IL 62225
Voice: (618) 22e-5040
DSN: 770-5040
Email address: joseph.dugan@us.army.mil Organizational E/Mail Box:
sddc.safb.safety@us.army.mil
Classification: UNCLASSIFIED
Caveats: FOUO
2
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