{"operation":"document","citation":"21-0013","title":"Hunting Titan — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2021-06-30","effective_on":null,"summary":"21-0013 response to Hunting Titan concerning 171.8, 172.102, 173.62.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-21-0013.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-21-0013.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-21-0013","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/75436/210013.pdf","body":"<<>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nJune 30, 2021\nMr. Joseph Murphy\nHunting Titan\n16825 Northchase Drive, Ste. 600\nHouston, TX 77060\nReference No. 21-0013\nDear Mr. Murphy:\nThis letter is in response to your February 8, 2021, letter requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to special provision\n114 for “UN0494, Jet perforating guns, charged, oil well, without detonator.” In your letter, you\nnote that—as provided by Special Provision 114 in § 172.102(c)(1)—jet perforating guns may be\nreclassed to Division 1.4 Compatibility Group D (1.4D) if: (1) the total weight of the explosive\ncontents of the shaped charges assembled in the guns does not exceed 90.5 kg (200 pounds) per\nvehicle; and (2) the guns are packaged in accordance with Packing Method US 1 as specified in\n§ 173.62. You state that your company would like to transport jet perforating guns containing\n400 pounds of explosive contents on two separate “vehicles” in a single shipment. Your\nproposed configuration consists of 200 pounds of explosive contents on a truck, with an\nadditional 200 pounds of explosive contents on a flatbed trailer attached to the truck. You ask\nwhether this proposed configuration complies with the HMR and whether the term “vehicle”—as\nused in Special Provision 114—refers to “transport vehicle” or “motor vehicle” as defined in\n§ 171.8.\nThe answer is no, your proposed configuration does not comply with the HMR. It is the opinion\nof this Office that the word “vehicle” as used in Special Provision 114 of § 172.102(c)(1) refers\nto the term “motor vehicle” as defined in § 171.8. Specifically, a “motor vehicle” means “a\nvehicle, machine, tractor, trailer, or semitrailer, or any combination thereof, propelled or drawn\nby mechanical power and used upon the highways in the transportation of passengers or\nproperty.”\n\n<<>>\n\nTherefore, a shipment of more than 200 pounds of explosive content would not be authorized on\na single motor vehicle.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nT. Glenn Foster\nChief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<>>\n\nWOLCOTT\nFrom: INFOCNTR (PHMSA)\nTo: Subject: Date: Attachments: Dodd, Alice (PHMSA); Hazmat Interps\nFW: Letter of Interpretation Request - Hunting Titan, Inc.\nTuesday, February 9, 2021 2:50:04 PM\nHunting Titan Letter of Interpretation Request.pdf\n21-0013\nDear Alice,\nPlease see the attached request for a letter of interpretation. Please contact our office with any\nquestions.\nThank you,\nSarah (HMIC)\nFrom: Joe Murphy [mailto:Joe.Murphy@Hunting-intl.com]\nSent: Monday, February 8, 2021 7:32 PM\nTo: INFOCNTR (PHMSA) \nSubject: Letter of Interpretation Request - Hunting Titan, Inc.\nCAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or\nopen attachments unless you recognize the sender and know the content is safe.\nTo whom it may concern,\nPlease see attached Letter of Interpretation request from Hunting Titan, Inc.\nRegards,\nJoseph Murphy - Compliance Manager / Distribution Center HSE\nHunting Titan, Inc.\n16825 Northchase Dr. Suite 600\nHouston,TX 77060\nOffice: 281-214-4500 Cell: 346-302-1607\nWIPE surfaces, WEAR mask, WATCH distance, WASH hands\nThis E-Mail is confidential and may also be subject to legal privilege. If you are not the\nintended recipient, do not copy, forward or use this E-Mail for any purpose, nor disclose its\ncontents to any other parties and notify us by return E-Mail. Warning Although this message\nhas been checked for all known viruses using Anti-Virus Software, © 2017 (all rights\nreserved), Hunting cannot accept responsibility for any loss or damage arising from the use of\nthis E-Mail or attachments. Information about the company can be found at\nhttp://www.hunting-intl.com\n\n<<>>\n\nFebruary 08, 2021\nHunting Titan\n16825 Northchase Drive, Suite 600\nHouston, TX 77060\nOffice 281-448-2200\nFax 281-448-2227\nwww.hunting-intl.com\nUS Department of Transportation\nPipeline and Hazardous Materials Safety Administration\n1200 New Jersey Ave. SE\nWashington, DC 20590\nSubject: Request of Letter of Interpretation\nTo whom it may concern,\nHunting Titan, Inc. respectfully request an interpretation of Special Provision 114 in 49CFR172.102.\nSP 114 Jet perforating guns, charged, oil well, without detonator may be reclassed to Division 1.4\nCompatibility Group 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.\nSpecifically, in (a) does the word vehicle refer to transfer vehicle? In 49CFR171.8 Transport\nvehicle means a cargo-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 (trailer, rail car, etc.)\nis a separate transport vehicle.\nOur question, can we transport a total weight of 90.5kg (200 pounds) of loaded jet perforating on one\nshipment but two separate transport vehicles? Our example is a truck with a flatbed trailer.\nYour consideration of this request is appreciated. Please let me know if additional information is\nneeded. I may be contacted at 346-302-1607 or joe.murphy@hunting-intl.com.\nRespectfully,\nJoseph Murphy\nJoseph Murphy\nCompliance Manager, Hazardous Materials\n\n<<>>\n\nFebruary 08, 2021\nHunting Titan\n16825 Northchase Drive, Suite 600\nHouston, TX 77060\nOffice 281-448-2200\nFax 281-448-2227\nwww.hunting-intl.com\nUS Department of Transportation\nPipeline and Hazardous Materials Safety Administration\n1200 New Jersey Ave. SE\nWashington, DC 20590\nSubject: Request of Letter of Interpretation\nTo whom it may concern,\nHunting Titan, Inc. respectfully request an interpretation of Special Provision 114 in 49CFR172.102.\nSP 114 Jet perforating guns, charged, oil well, without detonator may be reclassed to Division 1.4\nCompatibility Group 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.\nSpecifically, in (a) does the word vehicle refer to transfer vehicle? In 49CFR171.8 Transport\nvehicle means a cargo-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 (trailer, rail car, etc.)\nis a separate transport vehicle.\nOur question, can we transport a total weight of 90.5kg (200 pounds) of loaded jet perforating on one\nshipment but two separate transport vehicles? Our example is a truck with a flatbed trailer.\nYour consideration of this request is appreciated. Please let me know if additional information is\nneeded. I may be contacted at 346-302-1607 or joe.murphy@hunting-intl.com.\nRespectfully,\nJoseph Murphy\nJoseph Murphy\nCompliance Manager, Hazardous Materials","truncated":false,"body_characters":7366}