{"operation":"document","citation":"19-0091","title":"Baker Hughes — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2019-12-02","effective_on":null,"summary":"19-0091 response to Baker Hughes concerning 173.62.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-19-0091.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-19-0091.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-19-0091","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/72966/190091.pdf","body":"<<>>\n\n0\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nJesse Rodriguez\nBaker Hughes\nP.O. Box 546\nBay City, TX 77 404\nReference No. 19-0091\nDear Mr. Rodriguez:\nThis letter is in response to your July 9, 2019, email requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to labeling requirements for jet\nperforating guns (JPGs). Specifically, you ask for clarification oflabeling requirements when\nJPGs are palletized and banded together for transportation, and when several JPGs are assembled\ninto a \"staged gun-string\" prior to use. ·\nWe have paraphrased and answered your questions as follows:\nQ 1. You ask whether the individual gun body of a JPG requires a label when palletized and\nbanded together for transport.\nAl. The answer is yes. JPGs, whether classified as a 1. 1D or 1.4D explosive, are transported\nunder packaging instruction US 1, found in the Table of Packing Methods in§ 173.62.\nUS 1 requires that the motor vehicle transporting the JPG must have a specially built rack\nor carrying case. This rack or carrying case is the packaging for the JPG. Each rack or\ncarrying case must be labeled in accordance with Part 172, subpart D with the appropriate\nDivision 1.1 or 1.4 label.\nQ2. You ask whether the placement of a single hazard class label on a \"staged gun-string\"\nmeets the labeling requirements of the HMR.\n\n<<>>\n\nA2. The answer is yes. The \"staged gun-string\" would be treated as a single package, and\nduplicate labeling of each gun body making up the string would not be required in this\nscenario. It would, however, be permissible for each individual gun body in the string to\nbear the appropriate Division 1.1 or 1.4 label.\nI hope this information is helpful. Please contact us if we can be of further assistance.\ns&z~ JZZ:i!!\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<>>\n\nJanuary, lkeya CTR (PHMSA)\nFrom:\nSent:\nTo:\nSubject:\nAttachments:\nINFOCNTR (PHMSA)\nWednesday, July 10, 2019 3:22 PM\nHazmat Interps\nFW: Request for Interpretation - labeling requirements - UN0494 / NA0124\nPerfGunClassification(2017 .09.01).pdf\nHi Alice and lkeya,\nPlease see the request for a letter of interpretation below and the attached document.\nThanks,\nRobert, HMIC\nFrom: Rodriguez, Jesse [mailto:jesse.rodriguez3@bhge.com]\nSent: Tuesday, July 9, 2019 6:49 PM\nTo: INFOCNTR (PHMSA) ; INFOCNTR (PHMSA) \nCc: Rodriguez, Jesse \nSubject: Request for Interpretation - labeling requirements - UN0494 / NA0124\nGreetings,\nThis is a request for interpretation concerning the labeling requirements for UN0494, Jet perforating guns, charged, oil\nwell, without detonator and NA0124, Jet perforating guns, charged oil well, with detonator. See below questions.\n• Question 1. Does an individual gun body require a label when not assembled (See Exhibit A) - i.e. when\npalletized, banded together, for transport?\n• Question 2. When several gun bodies are assembled (See Exhibits Band C) (commonly referred to as a \"staged\ngun-string\" in the oil field), as one package, does the placement of one label meet the general labeling\nrequirements as outlined in 172.400 and 172.406, or do the individual gun bodies each require a separate label?\n• Exhibit A\nG S\nun ,vstem C omoonen s\nLabctl C:om1>ontrwt\nA Gun noav\n8 P ctrforator\nC Oetonatlna Cord\nD Exptoslve Transfer Devlee (eic:plO>>\n\n• Exhibits B and C\nThank you for your response. My contact information including my mailing address is attached to this message below.\nVery Respectfully Yours,\nJesse Rodriguez\nTransportation\nNorth America Land - Southern/ GOM\nBaker Hughes, a GE Company\nT: 832-726-8237\nE: jesse.rodriguez3@bakerhughes.com\nM: P.O. Box 546, Bay City, TX 77404\n2\n\n<<>>\n\nIME\ninstitute of makers of explosives\nGuide to Obtaining DOT Approval of Jet Perforating Guns\nusing AESC/IME Perforating Gun Specifications\nVersion 02\nEffective Date: September 1, 2017\n1.\n2.\nWhat is required?\nTransportation of Jet perforating guns (hereafter referred to as \"perforating guns\") in the USA is\nsubject to the provisions of the Hazardous Materials Regulations (HMR)1 of the U.S. Department\nof Transportation (DOT). In the HMR, DOT describes perforating guns as follows:\nJet perforating guns, charged, oil well, without detonator. Articles consisting of a\nsteel tube or metallic strip, into which are inserted shaped charges connected by\ndetonating cord, without means of initiation.\n2\nAs explosive devices, the following DOT requirements, administered by its Pipeline and Hazardous\nMaterials Safety Administration (PHMSA), apply to perforating guns:\n♦ Classification and approval\n♦ Registration of parties who offer and/or transport hazardous materials\n♦ Training of hazmat employees\n♦ Hazard communication (marking, labeling, placarding and shipping papers)\n♦ . Provision of emergency response information\n♦ Security plans\n♦ Packaging of hazardous materials\n• Modal transportation requirements\nThis document discusses classification and approval of perforating guns, specifically when using\nAESC/IME Perforating Gun Specifications.\nWhat are the AESC/IME Perforating Gun Specifications?\nBefore transporting or offering perforating guns for transport, they must be approved by the\nAssociate Administrator of PHMSA3\n. This approval, signified by a Classification of Explosives (also\nknown as EX-letter), sets forth the UN number, proper shipping name, UN division and compatibility\n1 49 CFR Subchapter C\n2 49 CFR 173.59\n3 49 CFR 173.51\n\n<<>>\n\nGuide to Obtaining DOT Approval of Jet Perforating Guns\nusing AESC/IME Perforating Gun Specifications\nPage 2\ngroup to be assigned to perforating guns as well as the terms and conditions for the use of said\nclassification.\n• Every perforating gun that is transported within the US must be approved by PHMSA before it\nmay be offered for transport.\n• Every person (company) that loads perforating guns and either transports them, or offers them\nfor transport, within the US must obtain approval from PHMSA before they do so.\nThe approval process can be expensive, complicated, and time-consuming , and often requires\ntesting by an approved laboratory before the approval application will be considered by PHMSA.\nThe Association of Energy Service Companies (AESC) and the Institute of Makers of Explosives\n(IME) have devised the AESC/IME Perforating Gun Specifications (see Annex 1) to provide a\nresource for reducing the expense, effort, and time required to obtain classification and approval of\nperforating guns.\nThe AESC/IME Perforating Gun Specifications are a series of documents setting forth standardized\nparameters for various perforating gun systems. These series of documents include a drawing\nrepresentative of the perforating gun system described, technical details for the system, authorized\ncomponents of the systems, and compliance requirements that govern the applicability of the\nperforating gun specification. The perforating gun systems covered by the AESC/IME Perforating\nGun Specifications are:\n• Ported tube systems (without detonator)\n• Tube & strip systems (without detonator)\n• Tube & tube systems (without detonator)\n• Strip carrier systems (without detonator)\n• Wire carrier systems (without detonator)\n• Link carrier systems (without detonator)\n• Swing carrier systems (without detonator)\n• Tube & Tube Kodiak™ system (without detonator)\nThe AESC/IME Perforating Gun Specifications have been previously reviewed and approved by PHMSA\nfor the use of perforating gun assemblers (see Annex 2). Approval applications submitted to PHMSA\nwhich fall within the parameters of these qualified perforating gun systems may therefore be processed\nwithout testing and with a minimum amount of effort and/or delay. Perforating guns that do not meet\nthe parameters of the AESC/IME Perforating Gun Specifications are subject to testing and the applicant\nmust follow the process described in 49 CFR 173.56.\n3. Classifications available using AESC/IME Perforating Gun Specifications\nClassification for perforating guns without detonators affixed to them may be obtained using the\nAESC/IME Perforating Gun Specifications:\n3.1. 1.1 D - PHMSA will issue approvals for qualifying perforating gun systems as UN01 24; JET\nPERFORATING GUNS, CHARGED; 1.10.\n\n<<>>\n\nGuide to Obtaining DOT Approval of Jet Perforating Guns\nusing AESC/IME Perforating Gun Specifications\nPage 3\n4.\n5. 3.2. 1 .4D - Excluding the Tube & Tube Kodiak™ system4\n, perforating gun systems that have\nbeen approved as UN0124 and that meet the requirements of Special Provision 1145 and\nPacking Method US 16 may be transported as UN0494: JET PERFORATING GUNS,\nCHARGED; 1.4D. See Annex 3 for the text of Special Provision 114 and Annex 4 for the\ntext of Packing Method US 1.\nATF License/Permit required7\nParties who seek authorization of perforating gun systems using the AESC/IME Perforating Gun\nSpecifications are advised that they must also be authorized by the Bureau of Alcohol, Tobacco,\nFirearms and Explosives (ATF)8 to possess explosives and must be in possession of the\nappropriate ATF license or permit. Within the scope of this document:\n4.1. Manufacturers must have an ATF type 20 license for each manufacturing location that will\nbe seeking PHMSA approval of perforating guns.\n4.2. Importers must have an ATF type 23 license for each importing location that will be seeking\nPHMSA approval of perforating guns.\n\\\n4.3. Dealers must have an ATF type 26 license for each dealing location that will be seeking\nPHMSA approval of perforating guns.\n4.4. Users must have an ATF type 33 permit. One type 33 permit per company is valid for all\nuser locations that the company operates within the USA.\nApproval of perforating gun systems\n5.1. General requirements\n5.1 .1. PE:lrforating guns to be approved using an AESC/IME Perforating Gun Specification\nmust be consistent with the configuration in the drawing of the applicable gun\nsystem.\n5.1.2. All explosive components to be loaded into perforating guns must themselves be\nPHMSA approved. Copies of these approvals must be maintained at each location\nwhere jet perforating guns are assembled .\n5.2. Approval application\n5.2.1 . A single application must be submitted for each perforating gun system to be\napproved. For example, if company A plans to utilize ported gun systems,\ntube/tube gun systems, and strip gun systems, then company A would submit 3\napproval applications. Once approved, the classification applies to all locations\n4 This exclusion is described in Note 5 of the Tube & Tube Kodiak™ specification sheet found in Annex 1.\n5 49 CFR 172.102\n6 49 CFR 173.62\n7 This notification is advisory only and is not a PHMSA imposed condition of jet perforating gun approvals\nissued pursuant to the AESC/IME Perforating Gun Specifications.\n8 U.S. Department of Justice\n\n<<>>\n\nGuide to Obtaining DOT Approval of Jet Perforating Guns\nusing AESC/IME Perforating Gun Specifications\nPage 4\noperated by the applicant (company A) that load the approved perforating gun\nsystems.\n5.2.2. Applications for approval of perforating guns using AESC/IME Perforating Gun\nSpecifications must:\n5.2.2.1. Identify the section of the HMR under which the application is submitted.\n5.2.2.2. Identify the applicant.\n5.2.2.3. Identify the perforating gun system to be approved.\n5.2.2.4. Identify the classification for which approval is desired.\n5.2.2.5. Identify the transport modes for which approval is desired.\n5.2.2.6. Include a copy of the AESC/IME Perforating Gun Specification that will\nserve as the basis for approval and contain a certification of adherence to\nthe specifications and requirements contained on that document.\nAnnex 5 contains an example application that is recommended for use in preparing\napplications in fulfillment of these requirements.\n5.3. Use of approval\nCompliance with applicable requirements of the HMR when shipping perforating guns\napproved using an AESC/IME Perforating Gun Specification is required, including, but not\nlimited to:\n5.3.1. Perforating guns cannot be transported or offered for transport until DOT has\nissued an approval in the form of a Classification of Explosives (EX-letter). A copy\nof the approval must be on file in every location from which loaded perforating guns\nare transported or offered for transport.\n5.3.2. All perforating guns approved using an AESC/IME Perforating Gun Specification\nmust always meet Packing Instruction US 1 of 49 CFR 173.62 (see Annex 4).\n5.3.3. All perforating guns approved as 1.10 (UN0124) using an AESC/IME Perforating\nGun Specification must always meet the requirements of Special Provision 114 of\n49 CFR 172.102 (see Annex 3) if offered as 1 .4D (UN0494 ).\n5.3.4. All shipments of perforating guns approved using an AESC/IME Perforating Gun\nSpecification must:\n5.3.4.1. comply with the DOT's shipping paper requirements found in 49 CFR 172,\nSubpart C;.\n5.3.4.2. comply with the DOT's marking requirements found in 49 CFR 172,\nSubpart D:\n\n<<>>\n\nGuide to Obtaining DOT Approval of Jet Perforating Guns\nusing AESC/IME Perforating Gun Specifications\nPage 5\n5.3.5. 5.3.4.3. comply with the DOT's labeling requirements found in 49 CFR 172,\nSubpart E; and\n5.3.4.4. must comply with DOT placarding requirements found in 49 CFR 172,\nSubpart F.\nAll persons transporting or offering for transport perforating guns approved using\nan AESC/IME Perforating Gun Specification must comply with the applicable\nportions of 49 CFR 172, Subparts G (Emergency Response Information), H\n(Training), and I (Safety and Security Plans).\n\n<<>>\n\nThis page is intentionally blank to facilitate 2-sided printing\n\n<<>>\n\nIME\ninstitute of makers of explosives\nGuide to Obtaining DOT Approval of Jet Perforating Guns\nusing AESC/IME Perforating Gun Specifications\nAnnex 1\nAESC/IME Perforating Gun Specifications\n(see next page)\n\n<<>>\n\nThis page is intentionally blank to facilitate 2-sided printing\n\n<<>>\n\nIME\ninstitute of makers of explos ives\nPerforating Gun Specification\nPorted Tube System (w/o Detonator)\nVersion : 02 (9/1/2017)\n,___E\n---B\nGun System Details\nMin Max\nSize\nLength (ft) 0.5 21\nDiameter (in) 2.500 6\nPerforators\n#/gun 1 81\nDevice NEW lal 2 39\nPerforating gun NEW (kg) 0.0020 3.1590\nDetonating Cord\nft/gun 0.5 26\nDevice NEW (gift) 3.89 5.18\nPerforating gun NEW (kg) 0.0019 0.1347\nExplosive Transfer Device (when present) (when present)\n#/gun 1 2\nDevice NEW lal 0.3 2\nPerforating gun NEW (kg) 0.0003 0.0040\nTotal Gun NEW (kg) 0.0042 3.2977\nNEW~ net explosive weight\nG S t C\nun ,ys em omponen ts\nLabel Component Comments\nA Gun body\nB Perforator\nC Detonating Cord\nD Explosive Transfer Device (explosive) Optional\nor Detcord End Seal (non-explosive) Optional\nE Alignment Plug & Sleeve\nF Lead Wire Optional\nNotes:\n1. Components B - D (explosive transfer device) must be DOT approved .\nSee Section 5.1.2 of Perforating Gun Approval Guide for verification requiremements.\n2. Drawing is a typical representation depicting major components of the specified\nperforating gun system. Actual details may vary. Additional, non-explosive components\nmay be present (for example: bull plugs, tandem subs, and/or alignment mechanisms).\nDrawing depicts a single gun. One or more guns may be connected together in tandem\nduring transport.\n3. Where Special Provision 114 of 49 CFR 172.102 applies, this perforating gun system may\nbe classed , marked, labeled, described, and transported as UN0494 (1 .40).\n4. Compliance with Packing Instruction US1 of 49 CFR 173.62 is required.\n5. Perforating guns are to be marked and labeled in accordance with 49 CFR, Part 172 prior to\ntransport.\nDangerous Goods Information (as assigned by DOT):\nEX-Number:\nUN No:\nDescription:\nLabel:\nAs assigned by DOT\nUN0124 (See also Note 3)\nJET PERFORATING GUNS, CHARGED\noil well, without detonator\n1.1 D (See also Note 3)\nAssociation of Energy Service Companies+ 121 S. Magnolia, Suite 103 ♦ Friendswood, TX 77546 + +1 (713) 781 -0758\nInstitute of Makers of Explosives+ 1212 New York Ave., NW, Suite 650 + Washington, DC 20005 + +1 (202) 266-4320\n\n<<>>\n\nThis page is intentionally blank to facilitate 2-sided printing\n\n<<>>\n\nIME\ninstitute of makers of explosives\nPerforating Gun Specification\nTube & Strip System (w/o Detonator)\nVersion : 02 (9/1/20 17)\nD\nA\nGun System Details\nMin Max\nSize\nLenath {ft) 1 31\nDiameter !in) 1.375 5\nPerforators\n#faun 1 180\nDevice NEW la\\ 1.5 32\nPerforatina aun NEW {kal 0.0015 5.7600\nDetonatlna Cord\nft/aun 1 35\nDevice NEW {a/ft) 1.62 5.18\nPerforatina aun NEW {kal 0.0016 0.1813\nExploslve Transfer Devices {when present) {when present)\n#faun 1 2\nDevice NEW !al 0.3 2\nPerforatina aun NEW {kal 0.0003 0.0040\nTotal Gun NEW {kal 0.0034 5.9453\nNEW = net explosive weight\nG S C un ;ystem omponents\nLabel Component Comments\nA Gun bodv\nB Perforator\nC Detonatina Cord\nD Explosive Transfer Device (explosive) Optional\nor Detcord End Seal {non-explosive) Optional\nE Lead Wire Optional\nF Carrier Strip Flat or Spiral\nNotes:\n1. Components B - D (explosive transfer device) must be DOT approved.\nSee Section 5.1.2 of Perforating Gun Approval Guide for verification requiremements.\n2. Drawing is a typical representation depicting major components of the specified\nperforating gun system. Actual details may vary. Additional, non-explosive components\nmay be present (for example: bull plugs, tandem subs, and/or alignment mechanisms).\nDrawing depicts a single gun. One or more guns may be connected together in tandem\nduring transport.\n3. Where Special Provision 114 of 49 CFR 172.102 applies, this perforating gun system may\nbe classed, marked , labeled, described, and transported as UN0494 (1 .4D).\n4. Compliance with Packing Instruction US1 of 49 CFR 173.62 is required.\n5. Perforating guns are to be marked and labeled in accordance with 49 CFR, Part 172 prior to\ntransport.\nDangerous Goods Information (as assigned by DOT):\nEX-Number:\nUN No:\nDescription:\nLabel:\nAs assigned by DOT\nUN0124 (See also Note 3)\nJET PERFORATING GUNS, CHARGED\noil well, without detonator\n1 .1 D (See also Note 3)\nAssociation of Energy Service Companies\n♦ 121 S. Magnolia, Suite 103 ♦ Friendswood, TX 77546 ♦ +1 (713) 781 -0758\nInstitute of Makers of Explosives ♦ 1212 New York Ave., NW, Suite 650 ♦ Washington, DC 20005 ♦ +1 (202) 266-4320\n\n<<>>\n\nThis page is intentionally blank to facilitate 2-sided printing\n\n<<>>\n\nIME\ninstitute of makers of explosives\nPerforating Gun Specification\nTube & Tube System (w/o Detonator)\nVersion: 02 (9/1/2017)\nGun System Details\nMin Max\nSize\nLength (ft) 0.75 31\nDiameter (In) 1.375 10\nPerforators\n#faun 1 744\nDevice NEW lal 1.5 61\nPerforatlna aun NEW lkal 0.0015 45.3840\nDetonatlna Cord\nftlaun 1 35\nDevice NEW (gfftl 1.62 5.18\nPerforating gun NEW (kg) 0.0016 0.1813\nExoloslve Transfer Devices (when present) (when present\n#faun 1 8\nDevice NEW /al 0.3 2\nPerforatlna aun NEW lkal 0.0003 0.0160\nTotal Gun NEW (kal 0.0034 45.5813\nNEW ~ net explosive weight\nG S t C\nun ,ys em omponents\nLabel Component Comments\nA Gun bodv\nB Perforator\nC Detonatlna Cord\nD Carrier Tube\nE Explosive Transfer Device (explosive) Optional\nor Detcord End Seal (non-explosive) Optional\nF Lead Wire Optional\n(not shown)\nNotes:\n1. Components B - C & E (explosive transfer device) must be DOT approved.\nSee Section 5. 1.2 of Perforating Gun Approval Guide for verification requiremements.\nC->-----------H-- E\n2. Drawing is a typical representation depicting major components of the specified\nperforating gun system. Actual details may vary. Additional, non-explosive components\nmay be present (for example: bull plugs, tandem subs, and/or alignment mechanisms).\nDrawing depicts a single gun. One or more guns may be connected together in tandem\nduring transport.\n3. Where Special Provision 114 of 49 CFR 172.102 applies, this perforating gun system may\nbe classed, marked, labeled, described, and transported as UN0494 (1 .4D).\n4. Compliance with Packing Instruction US1 of 49 CFR 173.62 is required.\nDangerous Goods Information (as assigned by con:\nEX-Number:\nUN No:\nDescription:\nLabel:\nAs assigned by DOT\nUN0124 (See also Note 3)\nJET PERFORATING GUNS, CHARGED\noil well, without detonator\n1.1 D (See also Note 3)\n5. Perforating guns are to be marked and labeled in accordance with 49 CFR; Part 172 prior to\ntransport.\nAssociation of Energy Service Companies\n♦ 121 S. Magnolia, Suite 103 + Friendswood, TX 77546 ♦ +1 (713) 781-0758\nInstitute of Makers of Explosives ♦ 1212 New York Ave. , NW, Suite 650 ♦ Washington, DC 20005 ♦ +1 (202) 266-4320\n\n<<>>\n\nThis page is intentionally blank to facilitate 2-sided printing\n\n<<>>\n\nPerforating Gun Specification\nIME\nins titute of makers of exp lo s ives\nStrip Carrier System (w/o Detonator)\nVersion: 02 (9/1/2017)\nA\nGun System Details\nMin Max\nSize\nLenath lftl 1 24\nDiameter llnl 1.375 3.5\nPerforators\n#/aun 1 144\nDevice NEW lal 2 39\nPerforatina aun NEW {kal 0.0020 5.6160\nDetonatlna Cord\nft/aun 1 28\nDevice NEW la/ftl 2.59 5.18\nPerforatina aun NEW lkal 0.0026 0.1450\nExoloslve Transfer Devices /when oresentl (when present1\n#/aun 1 2\nDevice NEW {al 0.3 2\nPerforatlna aun NEW!kal 0.0003 0.0040\nTotal Gun NEW (kal 0.0049 5.7650\nNEW= net explosive weight\nGun Svstem Comoonents\nLabel Comoonent Comments\nA Adaoter Optional\nB Detonatina Cord\nC Perforator\nD Carrier Strio Flat Twisted or Zia-Zaa\nE Explosive Transfer Device (explosive) Optional\nor Detcord End Seal lnon-exoloslvel Optional\nF Lead Wire Optional\n(not shown)\nNotes:\n1. Components B . C & E (explosive transfer device) must be DOT approved.\nSee Section 5.1.2 of Perforating Gun Approval Guide for verification requiremements .\nE\n2. Drawing is a typical representation depicting major components of the specified\nperforating gun system. Actual details may vary. Additional, non-explosive components\nmay be present (for example: bull plugs, tandem subs, and/or alignment mechanisms).\nDrawing depicts a single gun. One or more guns may be connected together in tandem\nduring transport.\n3. Where Special Provision 114 of 49 CFR 172.102 applies, this perforating gun system may\nbe classed, marked, labeled, described, and transported as UN0494 (1 .40).\n4. Compliance with Packing Instruction US1 of 49 CFR 173.62 is required .\nDangerous Goods Information (as assigned by DOTI:\nEX-Number:\nUN No:\nDescription:\nLabel:\nAs assigned by DOT\nUN0124 (See also Note 3)\nJET PERFORATING GUNS, CHARGED\noil well, without detonator\n1.1 D (See also Note 3)\n5. Perforating guns are to be marked and labeled in a=rdance with 49 CFR, Part 172 prior to\ntransport.\nAssociation of Energy Service Companies\nInstitute of Makers of E xplosives\n♦ 121 S. Magnolia, Suite 103 ♦ Friendswood, TX 77546 ♦ +1 (713) 781 -0758\n♦ 1212 New York Ave., NW, Suite 650 ♦ Washington, DC 20005 ♦ +1 (202) 266-4320\n\n<<>>\n\nThis page is intentionally blank to facilitate 2-sided printing\n\n<<>>\n\nIME\nins titute of makers of explos ives\n-A\n_\nF\nD\nE\nPerforating Gun Specification\nWire Carrier System (w/o Detonator)\nVersion: 02 (91112017)\nGun System Details\nMin\nMax\nSize\nLength (ft)\nDiameter (in)\nPerforators\n#/gun\nDevice NEW 1a1\nPerforating gun NEW (kg)\nDetonating Cord\nft/gun\nDevice NEW (gift)\nPerforating gun NEW (kg)\nTotal Gun NEW (kg)\nNEW = net explosive weight\n3\n1.000\n1\n0.5\n0.0005\n1\n2.59\n0.0026\n0.0031\nG S t C ts\nun ,ys em omponen\nLabel Component Comments\nA Adapter Optional\nB Detonating Cord\nC Perforator\nD Carrier Wire Two or more\nE Detcord End Seal (non-explosive) Optional\nF Lead Wire Optional\nNotes:\n1. Components B - C must be DOT approved. See Section 5.1.2 of Perforating Gun\nApproval Guide for verification requiremements.\n2. Drawing is a typical representation depicting major components of the specified\nperforating gun system. Actual details may vary. Additional, non-explosive components\nmay be present (for example: bull plugs, tandem subs, and/or alignment mechanisms).\nDrawing depicts a single gun. One or more guns may be connected together in tandem\nduring transport.\n3. Where Special Provision 114 of 49 CFR 172.102 applies, this perforating gun system may\nbe classed , marked, labeled, described, and transported as UN0494 (1 .4D).\n4. Compliance with Packing Instruction US1 of 49 CFR 173.62 is required.\n5. Perforating guns are to be marked and labeled in accordance with 49 CFR, Part 172 prior to\ntransport.\n70\n2.125\n150\n39\n5.8500\n72\n5.18\n0.3730\n6.2230\nDangerous Goods Information (as assigned by DOT):\nEX-Number:\nUN No:\nDescription:\nLabel:\nAs assigned by DOT\nUN0124 (See also Note 3)\nJET PERFORATING GUNS, CHARGED\noil well, without detonator\n1.1 D (See also Note 3)\nAssociation of Energy Service Companies\n♦ 121 S. Magnolia, Suite 103 ♦ Friendswood, TX 77546 ♦ +1 (713) 781 -0758\nInstitute of Makers of Explosives ♦ 1212 New York Ave., NW, Suite 650 ♦ Washington, DC 20005 ♦ +1 (202) 266-4320\n\n<<>>\n\nThis page is intentionally blank to facilitate 2-sided printing\n\n<<>>\n\nIME\ninstitute of makers of explosives\nPerforating Gun Specification\nLink Carrier System (w/o Detonator)\nVersion : 02 (9/1/2017)\nGun System Details\nMin Max\nA Size\nF Perforators\nE\nB\nC\nD\nLength (ft) 1\nDiameter (in) 1.250\n#/gun 1\nDevice NEW (g) 2\nPerforating gun NEW (kg) 0.0020\nDetonating Cord\nft/gun 1\nDevice NEW (gift) 5.18\nPerforating gun NEW (kg) 0.0052\nTotal Gun NEW (kg) 0.0072\nNEW= net explosive weight\nG S C un iystem omponents\nLabel Component Comments\nA Adapter Optional\nB Detonating Cord\nC Perforator\nD Charge Holder Two or more\nE Detcord End Seal (non-explosive) Optional\nF Lead Wire Optional\nNotes:\n1. Components 8- C must be DOT approved. See Section 5.1.2 of Perforating Gun\nApproval Guide for verification requiremements.\n2. Drawing is a typical representation depicting major components of the specified\nperforating gun system. Actual details may vary. Additional, non-explosive components\nmay be present (for example: bull plugs, tandem subs, and/or alignment mechanisms).\nDrawing depicts a single gun. One or more guns may be connected together in tandem\nduring transport.\n3. Where Special Provision 114 of 49 CFR 172.102 applies, this perforating gun system may\nbe classed , mar1>>\n\nThis page is intentionally blank to facilitate 2-sided printing\n\n<<>>\n\nIME\ninstit u t e of makers of explosives\nPerforating Gun Specification\nSwing Carrier System (w/o Detonator)\nVersion: 02 (9/1/2017)\nGun System Details\nMin Max\nSize\nLenath lftl 1 15\nDiameter linl 1.375 2.125\nPerforators\n#/aun 1 61\nDevice NEW /al 11 36\nPerforatina aun NEW lkal 0.0110 2.1960\nDetonatlna Cord\nft/aun 1.8 25\nDevice NEW la/ftl 2.59 3.89\nPerforatina aun NEW lkal 0.0047 0.0973\nTotal Gun NEW lkal 0.0157 2.2933\nNEW= net explosive weight\nC\nGun Svstem Comoonents\nLabel Comoonent Comments\nA Detcord End Seal lnon-exolosivel Optional\nB Detonatina Cord\nC Perforator\nD Carrier\nD\nNotes:\n1. Components B - C must be DOT approved. See Section 5.1.2 of Perforating Gun Approval\nGuide for verification requiremements.\n2. Drawing is a typical representation depicting major components of the specified\nperforating gun system. Actual details may vary. Additional, non-explosive components\nmay be present (for example: bull plugs, tandem subs, and/or alignment mechanisms).\nDrawing depicts a single gun. One or more guns may be connected together in tandem\nduring transport.\n3. Where Special Provision 11 4 of 49 CFR 172.102 applies, this perforating gun system may\nbe classed , marked, labeled, described, and transported as UN0494 (1.4D).\n4. Compliance with Packing Instruction US1 of 49 CFR 173.62 is required.\n5. Perforating guns are to be marked and labeled in accordance with 49 CFR, Part 172 prior to\ntransport.\nDangerous Goods Information (as assigned by DOT):\nEX-Number:\nUN No:\nDescription:\nLabel:\nAs assigned by DOT\nUN0124 (See also Note 3)\nJET PERFORATING GUNS, CHARGED\noil well, without detonator\n1.1 D (See also Note 3)\nAssociation of Energy Service Companies\n♦ 121 S. Magnolia, Suite 103 ♦ Friendswood, TX 77546 ♦ +1 (713) 781 -0758\nInstitute of Makers of Explosives ♦ 1212 New York Ave., NW, Suite 650 ♦ Washington, DC 20005 ♦ +1 (202) 266-4320\n\n<<>>\n\nThis page is intentionally blank to facilitate 2-sided printing\n\n<<>>\n\nIME Perforating Gun Specification\ninstitute of make rs of explosives Tube & Tube Kodiak TM System (w/o Detonator)\nVersion: 02 (9/1/2017)\nGun System Details\nMin Max\nSize\nLength (ft) 0.75 21\nDiameter (in) 1.563 4.5\nPerforatons\n#/gun 1 80\nDevice NEW (g) 1.5 39\nPerforatina aun NEW (kal 0.0015 3.1200\nDetonatina Cord\nft/gun 1 25\nDevice NEW (a/ft) 1.62 5.18\nPerforatina aun NEW (kal 0.00162 0.1295\nExolosive Transfer Devices lwhen oresentl lwhen oresentl\n#/gun 1 2\nDevice NEW ,m 0.3 2\nPerforatina aun NEW lkal 0.0003 0.0040\nKodiak Disks\n#/gun 1 60\nKodiak Disk NEW (al 5.0000 110.0000\nPerforatina aun NEW lkal 0.0050 6.6000\nTotal Gun NEW (kg) 0.0084 9.8535\nNEW= net explosive weight\nG S C un ;vstem omoonents\nLabel Component Comments\nA Gun body\nB Perforator\nC Detonatina Cord\nD Carrier Tube\nE Explosive Transfer Device (explosive) Optional\nor Detcord End Seal lnon-exolosivel Ootional\nF Lead Wire Optional\n(not shown)\nG Kodiak Disk See note 6\nNotes:\n1. Components B - C, E (explosive transfer device), & G must be DOT approved.\nSee Section 5.1.2 of Perforating Gun Approval Guide for verification requiremements.\n2. Drawing is a typical representation depicting major components of the specified\nperforating gun system. Actual details may vary. Additional, non-explosive components\nmay be present (for example: bull plugs, tandem subs, and/or alignment mechanisms).\nDrawing depicts a single gun. One or more guns may be connected together in tandem\nduri ng transport.\n3. Compliance with Packing Instruction US1 of 49 CFR 173.62 is required .\nDangerous Goods Information (as assigned by DOT):\nEX-Number:\nUN No:\nDescription:\nLabel:\nAs assigned by DOT\nUN0124\nJET PERFORATING GUNS, CHARGED\noil well, without detonator\n1.1D\n4. Perforating guns are to be mar1>>\n\nThis page is intentionally blank to facilitate 2-sided printing\n\n<<>>\n\nIME\ninstitute of makers of explosives\nGuide to Obtaining DOT Approval of Jet Perforating Guns\nusing AESC/IME Perforating Gun Specifications\nAnnex 2\nPHMSA Approval of AESC/IME Specifications\nThis document may be retrieved from the following :\nhttps://www.ime.org/uploads/public/PHMSA/PHMSAApprovalJPGStandard2017.09.01 .pdf\n\n<<>>\n\nThis page is intentionally blank to facilitate 2-sided printing\n\n<<>>\n\nIME\ninstitute of makers of explosives\nGuide to Obtaining DOT Approval of Jet Perforating Guns\nusing AESC/IME Perforating Gun Specifications\nAnnex 39\nText of Special Provision 114 of 49 CFR 172.102\n(as of February 15, 2017)\n114 Jet perforating guns, charged, oil well, without detonator may be reclassed to Division 1.4 Compatibility\nGroup D (1 .4D) if the following conditions are met:\na. The total weight of the explosive contents of the shaped charges assembled in the guns does not\nexceed 90.5 kg (200 pounds) per vehicle; and ·\nb. The guns are packaged in accordance with Packing Method US 1 as specified in §173.62 of this\nsubchapter.\n9 This text is provided here as a convenience to the reader; however, the version published in the\ncurrently effective CFR is the version that applies to use of the AESC/IME Perforating Gun Specifications.\n\n<<>>\n\nThis page is intentionally blank to facilitate 2-sided printing\n\n<<>>\n\nIME\ninstitute of makers of explosives\nGuide to Obtaining DOT Approval of Jet Perforating Guns\nusing AESC/IME Perforating Gun Specifications\nAnnex 4\nText of Packing Method US 1 of 49 CFR 173.62\n(as of February 15, 2017)10\n1. A jet perforating gun, charged, oil well may be transported under the following conditions:\na. b. c. d. e. Initiation devices carried on the same motor vehicle or offshore supply vessel must be segregated;\neach kind from every other kind, and from any gun, tool or other supplies, unless approved in\naccordance with §173.56. Segregated initiation devices must be carried in a container having\nindividual pockets for each such device or in a fully enclosed steel container lined with a non-\nsparking material. No more than two segregated initiation devices per gun may be carried on the\nsame motor vehicle.\nEach shaped charge affixed to the gun may not contain more than 112 g (4 ounces) of explosives.\nEach shaped charge if not completely enclosed in glass or metal, must be fully protected by a metal\ncover after installation in the gun.\nA jet perforating gun classed as 1.1 D or 1.40 may be transported by highway by private or contract\ncarriers engaged in oil well operations.\n(i) A motor vehicle transporting a gun must have specially built racks or carrying cases designed\nand constructed so that the gun is securely held in place during transportation and is not subject\nto damage by contact, one to the other or any other article or material carried in the vehicle;\nand\n(ii) The assembled gun packed on the vehicle may not extend beyond the body of the motor\nvehicle.\nA jet perforating gun classed as 1 .4D may be transported by a private offshore supply vessel only\nwhen the gun is carried in a motor vehicle as specified in paragraph (d) of this packing method or\non offshore well tool pallets provided that:\n(i) All the conditions specified in paragraphs (a), (b), and (c) of this packing method are met;\n(ii) The total explosive contents do not exceed 90.8 kg (200 pounds) per tool pallet;\n(iii) Each cargo vessel compartment may contain up to 90.8 kg (200 pounds) of explosive content\nif the segregation requirements in §176.83(b) of this subchapter are met; and\n10 This text is provided here as a convenience to the reader; however, the version published in the\ncurrently effective CFR is the version that applies to use of the AESC/IME Perforating Gun Specifications.\n\n<<>>\n\n(iv) When more than one vehicle or tool pallet is stowed \"on deck\" a minimum horizontal separation\nof 3 m (9.8 feet) must be provided.\n\n<<>>\n\nIME\ninstitute of makers of explosives\nGuide to Obtaining DOT Approval of Jet Perforating Guns\nusing AESC/IME Perforating Gun Specifications\nAnnex 5\nExample Application Format\n(see next page)\n\n<<>>\n\nThis page is intentionally blank to facilitate 2-sided printing\n\n<<>>\n\nDate\nOptional document ID\nAssociate Administrator for Hazardous Materials Safety\nPipeline and Hazardous Materials Safety Administration\nU.S. Department of Transportation\nOffice of Approvals and Special Permits, PHH-32\nEast Building\n1200 New Jersey Avenue, SE\nWashington, DC 20590-0001\nSubject: Approval Application - Perforating Gun\nSystem using AESC/IME Perforating Gun\nSpecification (Ver. 02, Effective: 9/1/2017)\nDear Associate Administrator:\nApplication for an explosives approval as described below is submitted. In compliance with 49 CFR\n107.705, the following information is provided:\nA. Section under which application is made\n49 CFR §173.51(a) , §173.56(b)(1), and §173.58\nB. Approval, registration, or exemption number\nEX-number to be assigned.\nC. Name, address, and telephone number of the applicant\nApplicant Name:\nApplicant Mailing Address:\nContact Name:\nContact Phone Number:\nContact Fax Number:\nContact E-mail Address:\nD. Product Identification\nThe product to be approved is described as (check only one entry and, if \"Other\" checked, fill in blank) :\nD Please use Applicant Name (Section C) + System Name + Division (Section D)\nD Other (please specify):\n- ------- ------------------\n\n<<>>\n\nI\nE. System to be Approved and Classification Sought\nApproval of the following AESC/IME Perforating Gun Specification Gun System (check only one entry):\nD Ported tube systems\nD Tube & strip systems\nD Tube & tube systems\nD Strip carrier systems\nD Wire carrier systems\nD Link carrier systems\nD Swing carrier systems\nD Tube & tube Kodiak™ system\nClassification sought:\nUN0124, 1.1 D, Jet Perforating Guns, Charged, Oil Well\nF. Proposed duration of approval\nConsistent with current DOT policy.\nG. Transport mode(s) affected\nCheck all that apply:\nD Highway\nD Cargo-only Rail\nD Vessel\nH. Certification\nBy my signature below, I certify that I have reviewed the AESC/IME Perforating Gun Specification indicated\nin Section D above and confirm that my perforating gun system meets the graphical representation, the\ntechnical specifications, and compliance requirements contained thereon .\nSincerely,\nName\nTitle\nAttachments: AESC/IME Perforating Gun Specification (Ver. 02, Effective 7/31/2017)","truncated":false,"body_characters":37908}