Dyno Nobel Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, D.C. 20590 FEB 2 7 2013 Mr. J.D. Thomas Dyno Nobel Inc. Simsbury Plant 660 Hopmeadow Street Simsbury, CT 06070 Reference No. 12-0216 Dear Mr. Thomas: This is in response to your e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR 171-180) applicable to the packaging for transportation of non- electric detonators. In your letter, you state that the detonators are packaged in a 4G fiberboard "outer" box in a manner that protects and prevents movement of the articles. You also state that the detonator assemblies have a shock tube that is wound in a loop or figure 8 configuration and that they have voids between the coils due to the coils overlapping each other. You ask whether a 4G fiberboard box used as a single packaging for non-bulk materials is a receptacle and whether it would be considered a one-time use receptacle. You also present your concern regarding the requirement to fill the box to 95% when testing. The 4G fiberboard box is not a receptacle in the context of§ 178.602. Your package is a combination package with the articles being the inner packages and the 4G fiberboard box being the outer package. The 95% fill requirement does not apply to articles and, therefore, the testing should take place with the 4G fiberboard box filled as it would be prepared for transportation or as otherwise specified in§ 173.602. You must also determine whether additional cushioning, etcetera, should be included in the package and otherwise ensure conformance with§§ 173.24 and 173.24a for general requirements for non-bulk packagings and packages. With respect to reuse, to reuse a packaging, you must ensure that it conforms to§ 173.28, which in part requires that packagings and receptacles used more than once must be in such condition, including closure devices and cushioning materials, that they conform in all respects to the prescribed requirements of the HMR. If your packaging does not conform to#

Page 2Drakeford, Carolyn (PHMSA) From: Sent: To: Subject: Attachments: Eckenrode, Andrew.CTR (PHMSA) on behalf of INFOCNTR (PHMSA) Wednesday, September 26, 2012 2:32PM Drakeford, Carolyn (PHMSA) FW: interpretation pic19629.jpg Carolyn, We received the following request for a formal letter of interpretation Thanks Andrew -----Original Message----- From: jd.thomas@am.dvnonobel.com [mailto:jd.thomas@am.dynonobel.coml Sent: Monday, September 24, 2012 1:50 PM To: INFOCNTR (PHMSA) Subject: interpretation Dear Hazardous Material Information Center: Is a 4G fiberboard box used as outer packaging in non-bulk packaging in a single packaging configuration (meaning it does not have any inner packaging) considered a receptacle? Would it be also considered a one time use receptacle? I package non-electric detonators in a 4G fiberboard outer box that are packaged in such a way that the fit prevents freedom of movement and protects the articles from sources of impact. The detonator assemblies have shock tube that is wound in a loop or figure 8 configuration. When these articles are packed in the box they are snug and once the box is full, we can not put more units in the box. The units do have voids between the coils as the coils overlap each other. A DOT inspector for our UN POP test facility states that the detonator assemblies do not fill the box to 95% of its volume (required for a receptacle) because of these small voids. This inspector believes that the outer box is a receptacle and/or a one time use receptacle and therefore can not be used for my articles and can only be tested as a receptacle at 95% capacity (which has the definition of volume) . We can not put in another unit, it would burst the box. Again- is a single packaging 4G fiberboard box used for non-bulk materials a receptacle? (Embedded image moved to file: pic19629.jpg) You can see the voids where coils of shock tube complete their figure 8 pattern. The units do not compress and fill the box to a good snug fit. Best regards, J.D. Thomas Global Product Management Support I Integration+ Packaging+ Change Management 1#

Page 3Dyno Nobel Inc. A business of lncitec Pivot Limited Simsbury Plant, 660 Hopmeadow Street, P.O. Box 2006, Simsbury, CT 06070, USA Office: +1860 4081839 I Fax: +1860 4081983 I Mobile: +1860 713 3013 mailto:jd.thomas@am.dynonobel.com http:ljwww.dynonobel.com Groundbreaking Performance Through Practical Innovation Confidentiality Notice: The information contained in this e-mail (including any attachments) may contain confidential and/or privileged information. If you are not an intended recipient you must not use, disclose, disseminate, copy or print its contents. If you receive this e-mail in error, please notify the sender by reply e-mail and delete this message from your system. Dyno Nobel does not undertake liability for any damage sustained as a result of software viruses and advises that you carry out your own virus checks before opening any attachment. 2#