Guidanceguidance
11-0166
Con-way Freight — Hazardous Materials Safety Interpretation
Current as of source date Government source
RegulusPipeline researchRegulusPipeline research11-0166
Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave .. SE Washington. DC 20590 Ms. Marie Easley-Cook Safety Analyst Associate Con-way Freight 2211 Old Earhart Road Ann Arbor, MI 48105 SEP 1 5 2011 Ref. No.: 11-0166 Dear Ms. Easley-Cook: This responds to your July 1, 2011 letter regarding the requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of explosives. Your reference letter of interpretation number 08-0192 in which the Pipeline and Hazardous Materials Safety Administration (PHMSA) stated that "Division lA materials (other than Division 1A detonating cord) may be transported on the same motor vehicle as detonators without meeting the conditions specified in paragraphs (g)(1) thru (g)(3) of § l77.848(g), provided they are authorized for such transportation in the compatibility table for Class 1 materials in § 177.848(f)." You present a scenario where UN 0440, Charges, Shaped, lAD are shipped with UN 0255, Detonators, Electric, lAB, in the same trailer. You ask if these two materials can be shipped together in transportation. The materials you describe may only be transported on the same motor vehicle if the requirements of § 177.835(g)(l), (2), and (3) are met. The compatibility chart in § 177.848(f) generally does not allow lAD and lAB materials to be shipped on the same vehicle but references the reader to Note 4. Note 4 directs the reader to § l77.835(g) which prohibits the transportation of detonators on the same motor vehicle with any Division 1.1, 1.2, or 1.3 material (except other detonator assemblies, boosters with detonators or other detonators), explosives for blasting, or detonating cord Division lA material. I hope this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, '/$ ~-:2 ( ~Y~,r")'l/)L;-VtAU£" T. Glenn Foster Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#
Page 2Andrews ~111·i4g § 111 · ~3::> ~plosj ves. July 1,2011 ll-Dlftfp Mr. Charles E. Setts Director, Office of Hazardous Materials Standards U.S. DOT/PHMSA (PHH-10) 1200 New Jersey Avenue, SE East Suilding, 2nd Floor Washington, DC 20590 Mr. Setts: I am requesting clarification on a letter of interpretation dated April 1 , 2010, Reference No. 08-0192, in regards to a shippers request for transportation of explosives. Paragraph three states "Division 1.4 materials (other than Division 1.4 detonating cord) may be transported on the same motor vehicle as detonators without meeting the conditions specified in paragraphs (g)(1) thru (g)(3) of 177.835(g) provided they are authorized for such transportation in the compatibility table for Class 1 materials in 177.848(f)". The scenario that I present is the transportation of UN0440, Charges, Shaped, 1.40, with UN0255, Detonators, Electric, 1.4S, in the same trailer. Applying the passage from the aforementioned letter, the 1.40 (Charges, Shaped) material can be shipped with the 1.4S (Detonators, Electric),lf the compatibility table authorizes it. After checking the compatibility table for Class 1 (Explosive) materials in 177.848(f), an "X" is located where "S" and "0" meet. Therefore, following the instructions in 177.848(g)(2), "The letter "X" in the table indicates that explosives of different compatibility groups may not be carried on the same transport vehicle," these materials cannot be transported together. Is this correct? Can these explosive materials be transported together? Thank you for your assistance . . Regards, a & ~l~ook ady-~ Safety Analyst Associate Con-way Freight 2211 Old Earhart Road Ann Arbor, MI 48105#
Page 3U.S. Department of Transportation 1200 New Jemy Ave, S.t. Washington. D.C. 20590 Pipeline and Hazardous Materials Safety Administration Ms. Shelly Espinoza Titan Specialties, Ltd. 143 HCR 4361 Milford, Texas 76670 Ref. No. 08-0192 Dear Ms. Espinoza: This responds to your e-mail request for clarification of the segregation requirements for explosives under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether a typographical error exists in the introductory text of § 177 .835(g) with regard to the transportation of Division 1.4 explosive materials, other than Division 1.4 detonating cord, on the same transport vehicle as detonators (except other detonators, detonator assemblies or boosters with detonators). It is your understanding that because there is no comma between the words "detonating cord" and "Division 1.4 material" in both sentences of the introductory text where they appear, it inadvertently prohibits the transportation of Division 1.4 material, other than Division 1.4 detonating cord, on the same transport vehicle as detonators under the conditions specified in the remainder of the paragraph. I apologize for the delay in responding and any inconvenience it may have caused. Your understanding is not correct. Section 177.835(g) establishes requirements for loading various types of explosive materials on the same transport vehicle. In accordance with this section, detonator assemblies or boosters may not be transported on the same motor vehicle as explosive material assigned to Division 1.1., 1.2, or 1.3; detonating cord that is assigned to Division 1.4; or explosive material assigned to Division 1.5. Division 1.4 materials (other than Division 1.4 detonating cord) may be transported on the same vehicle as detonator assemblies or boosters provided they are authorized for such transportation in the compatibility table for Class 1 materials in § 177.848(1). Section 177 .835(g) authorizes detonators to be transported on the same motor vehicle as explosive material assigned to Division 1.1., 1.2, or 1.3; detonating cord that is assigned to Division 1.4; or explosive material assigned to Division 1.5 under the conditions specified in paragraphs (g)(1) thru (g)(3). Division 1.4 materials (other than Division 1.4 detonating cord)#
Page 4may be transported on the same motor vehicle as detonators without meeting the conditions specified in paragraphs (g)(l) thru (g)(3) of § 177.835(g) provided they are authorized for such transportation in the compatibility table for Class 1 materials in § 177.848(1). I trust this satisfies your inquiry. Please contact us if we can be of further assistance. Sincerely, " J~~;7r-A+" , , .., ! r /..' ' Itr",·. . Hattie L. Mitchell Chief, Regulatory Review and Reinvention Office of Hazardous Materials Standards#
This material provides agency context. It does not replace binding regulatory text, and its legal effect depends on the underlying authority and facts.