{"operation":"document","citation":"18-0123","title":"Jet Research Center — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2019-05-09","effective_on":null,"summary":"18-0123 response to Jet Research Center concerning 171.8, 173.56, 173.62, 177.835, 177.848.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-18-0123.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-18-0123.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-18-0123","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/71621/180123.pdf","body":"<<>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nMAY O 9 2019\nMark Cipolla\nMaterial Coordinator, Logistics\nJet Research Center\n8432 S I-35W\nAlvarado, TX 76009-9775\nReference No. 18-0123\nDear Mr. Cipolla:\nThis letter is in response to your September 6, 2018, email requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to segregation of\nexplosives. Specifically, you indicate that a motor vehicle combination consisting of a flatbed\ntruck towing a flatbed trailer is transporting the following explosive materials:\n• \"UN0255, Detonators, electric,/or blasting, 1 .4B\" and \"UN0454, Igniters, 1 .4S\"\npackaged in 4G fiberboard boxes that are further overpacked on a wood pallet and\nplaced on the flatbed truck.\n• \"UN0494, Jet perforating guns, 1.4D\" are placed on the flatbed trailer.\nWe have paraphrased and answered your questions as follows:\nQ 1. You ask if the motor vehicle configuration of the flatbed truck towing a flatbed trailer is\nconsidered a single transport vehicle.\nAl. The answer is no. There are two definitions that need to be considered-transport\nvehicle and motor vehicle. In your scenario, you have two transport vehicles that make\nup a motor vehicle. In accordance with § 171.8, a transport vehicle is defined as \"a\ncargo-carrying vehicle such as an automobile, van, tractor, truck, semitrailer, tank car or\nrail car used for the transportation of cargo by any mode. Each cargo-carrying body\n(trailer, rail car, etc.) is a separate transport vehicle.\" Therefore, the flatbed truck and the\nflatbed trailer are each considered a separate transport vehicle.\nFurthermore, § 171.8 defines a motor vehicle as \"a vehicle, machine, tractor, trailer, or\nsemitrailer, or any combination thereof, propelled or drawn by mechanical power and\nused upon the highways in the transportation of passengers or property.\" Therefore, the\nflatbed truck and the flatbed trailer combination is considered a single motor vehicle.\n\n<<>>\n\nQ2. A2. You ask if the segregation method described in your request complies with the HMR,\nparticularly in relation to packing instruction US 1.\nIn accordance with the segregation table in§ l 77.848(f) and explanatory language in\n§ 177 .848(g):\n• \"UN0255, Detonators, electric,far blasting, 1 .4B\" and \"UN0494, Jet perforating\nguns, 1 .4D,\" are not authorized for transport on the same transport vehicle.\n• \"UN0255, Detonators, electric,far blasting, 1 .4B\" and \"UN0454, Igniters, 1 .4S\"\nmay be transported together on the same transport vehicle.\n• \"UN0494, Jet perforating guns, 1 .4D\" and \"UN0454, Igniters, 1 .4S\" may be\ntransported together on the same transport vehide.\nFurthermore, because your situation includes the transportation of detonators, it may be\nsubject to additional motor vehicle segregation requirements under § 177 .83 5(g) (see ·\n§ 177.848(g)(3)(iv)). Since the only other explosives in your example are classed as\nDivision 1.4 hazardous materials and are not detonating cord, the restrictions in\n§ l 77.835(g) prohibiting the transportation on the same motor vehicle do not apply.\nTherefore, the combination of \"UN0255, Detonators, electric,far blasting, 1 .4B,\"\n\"UN0494, Jet perforating guns, 1 .4D,\" and \"UN0454, Igniters, 1 .4S\" may be transported\ntogether on the same motor vehicle.\nAdditionally, because the shipment contains \"UN0494, Jet perforating guns, 1 .4D,\"\nsegregation requirements of§ 173.62 packing instruction US 1 must also be met. In\naccordance with paragraph 1.a. of packing instruction US 1, initiation devices carried on\nthe same motor vehicle must be segregated ( each kind from every other kind) and from\nany gun, tool or other supplies, unless approved in accordance with§ 173.56. The\nsegregated initiation devices must be carried in a container having individual pockets for\neach such device or in a fully enclosed steel container lined with a non-sparking material\nand no more than two segregated initiation devices per gun may be carried on the same\nmotor vehicle.\n\n<<>>\n\nBased on the information provided in your request it is the opinion of this Office that the\nscenario described in your request meets the segregation requirements of the HMR, as\nlong as the initiation devices ( detonators and igniters) are appropriately segregated and\ntransported in the appropriate containers specified in US 1, unless approved by the\nAssociate Administrator, and no more than two detonators per jet perforating gun are\ntransported on the motor vehicle. Please note that all other packaging and securement\nrequirements outlined in US 1, along with other applicable HMR requirements, must be\nmet.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely, d,\n,,.._,,___,,,,z£t:\nrk er Ki eren\nChief, Standards Development\nStandards and Rulemaking Division\n\n<<>>\n\nl~---0123\nDodd, Alice (PHMSA)\nFrom:\nSent:\nTo:\nSubject: INFOCNTR (PHMSA)\nFriday, September 07, 2018 3:53 PM\nHazmat Interps\nFW: CFR 49 Part 173.62 Transportation of Jet Perforating Guns by Highway\nHi Alice and lkeya,\nBelow is a request for a letter of interpretation.\nI spoke with the caller and Eamonn about the segregation table. He specifically wants in writing how Packing Instruction\nUS1 relates to this situation.\nThanks,\nJonathon, HMIC\nFrom: Mark Cipolla [mailto:Mark.Cipolla@Halliburton.com]\nSent: Thursday, September 06, 2018 5:27 PM\nTo: PHMSA HM lnfoCenter \nCc: Michael Farley ; Donte Villery ; Brian Kelley\n; Darren Walters \nSubject: RE: CFR 49 Part 173.62 Transportation of Jet Perforating Guns by Highway\nHi,\nWith the below situation and the subject line using US1 for transportation of Jet perforating guns can you please\nprovide literature on t his subject?\nFrom: Mark Cipolla\nSent: Thursday, September 06, 2018 6:50 AM\nTo: phmsa.hm-infocenter@dot.gov\nCc: Michael Farley; Donte Villery; Brian Kelley; Darren Walters\nSubject: CFR 49 Part 177 Transportation of Hazardous Material by Highway\nHi,\nI'm trying to transport UN0494, Jet perforating guns, 1.4D with UN0255, Detonators, electric, 1.4B and UN0454, lgniters,\n1.4S. I'm want to put them on a flatbed truck towing a flatbed trailer. The detonators and igniters are packed in\nfiberboard 4G boxes on a wood pallet wrapped. The guns will be transported on the flatbed trailer and the detonators\nand igniters will be transported on the flatbed truck towing the trailer. Is this truck and trailer considered one unit or\ntwo and is this legal to do?\nMark Cipolla\nMaterial Coordinator, Logistics\nJet Research Center\n8432 S l-35W\nAlvarado, TX 76009-9775\nEmail: mark.cipolla@halliburton.com\nOffice: +1 817-761-2065\nMobile: +1 817-648-1207\n1","truncated":false,"body_characters":6897}