{"operation":"document","citation":"21-0030","title":"Wellmatics — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2021-08-19","effective_on":null,"summary":"21-0030 response to Wellmatics concerning 172.406, 173.304.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-21-0030.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-21-0030.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-21-0030","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/standards-rulemaking/hazmat/interpretations/75746/210030.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nAugust 19, 2021\nMr. Joshua Howk\nWellmatics\n6770 McHard Road\nHouston, TX 77053\nReference No. 21-0030\nDear Mr. Howk:\nThis letter is in response to your March 22, 2021, letter requesting clarification of the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180) applicable to labeling and marking\nrequirements for jet perforating guns (JPGs). You provide an overview of your process for JPG\nloading and preparation for transportation and state that, when multiple JPGs are palletized, the\nrequired labels and markings are not always visible and/or may not be applied. Furthermore, you\nprovide images of a potential solution; specifically, an extended threaded end cap design that\nwould allow space for placement of the required label(s) and marking(s) without having to\nremove the JPG from a pallet. You ask whether the placement of a label and marking on the\nextended threaded end cap—for each individual JPG on a pallet—meets the labeling and\nmarking requirements of the HMR.\nThe answer is yes. As provided in §§ 172.304 and 172.406, respectively, each marking must be\nprinted on or affixed to the surface of a package or on a label, tag, or sign; and each label must be\nprinted on or affixed to a surface (other than the bottom) of the package or containment device\ncontaining the hazardous material and near the proper shipping name marking.\n\n<<<PAGE 2>>>\n\nProvided each individual JPG on a pallet is labeled and marked—either on the body of the JPG\nor on its extended threaded end cap—this practice would be in compliance with the HMR.\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nDirk Der Kinderen\nChief, Standards Development Branch\nStandards and Rulemaking Division\n\n<<<PAGE 3>>>\n\nCardez\n21-0030\nFrom: INFOCNTR (PHMSA)\nTo: Subject: Date: Dodd, Alice (PHMSA); Hazmat Interps\nFW: Interpretation request for explosive label sticker placement on jet perforating guns\nMonday, March 22, 2021 3:55:48 PM\nAttachments: image008.png\nimage001.png\nimage011.png\nimage012.png\nimage013.png\nGood afternoon Alice,\nPlease see the request for a letter of interpretation below. Please contact our office with any\nquestions.\nThank you,\nSarah, HMIC\nFrom: Joshua Howk [mailto:josh.howk@wellmatics.com]\nSent: Monday, March 22, 2021 1:40 PM\nTo: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov>\nSubject: Interpretation request for explosive label sticker placement on jet perforating guns\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.\nU.S. Department of Transportation\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nUnited States\nTo Whom it may concern:\nWellmatics is a manufacturer for the oil and gas industry and provides products\nto service companies for perforating in oil and gas wells.\nThese products include perforating systems and assemblies.\nWe are looking for an interpretation on the explosive labeling of jet perforating\nguns sticker placement location.\n\n<<<PAGE 4>>>\n\nHere is some information that will give detail to what interpretation we are\nrequesting.\nThe physical perforating gun is comprised of three parts. Outside tubular body\nor carrier, inner charge holder tube or strip, and threaded end protectors on both\nends.\nThese are sent to the users by manufacturers on pallets and or racking for the\nuser to load explosives into for oilfield perforating operations.\nThis is the steps followed by the users to load and prepare for transport:\nFollowing API RP 67 for explosive loading\n· The user would remove one of the threaded end caps to pull out the inner\ncharge tube and or strip.\n· The user would take the inner charge tube or strip out of the carrier or outer\ntube body.\n· Then the user will load explosive shape charges and detonating cord in the\ninner charge tube or strip holder.\n· The user will insert back into the carrier or outer tube body.\n· The user will replace the threaded end cap to hold inner charge tube or strip in\nplace\nWe now have a loaded jet perforating gun-\n\n<<<PAGE 5>>>\n\nThe label sticker that shows the explosive classification, UN number, description,\nand company address is placed on the carrier outside tube.\nWith typical pallets and or racking there are between 50-100 loaded perforating\nguns for each pallet or rack.\nThe users are moving thousands of these per week, and we have noticed a few\nobservations.\nThe user is responsible for attaching the label sticker to each unit to comply the\nregulation for labeling for transportation.\nThe problem arises as the physicality and time of moving these in order to label\neach one individually- this is not happening.\nWe are seeing only partial labeling of the guns on the pallet, labeling the exterior\nonly, and or worse not being labeled at all.\nWellmatics strongly recommends to the user to comply with the individual labeling\nbut has no authority in the matter so we are seeking to engineer a solution to prevent\na lack of compliance.\nIn order to label each individual gun body the user must physically remove from\nthe pallet that they are provided on.\nThis should but often does not happen and the reasoning is listed below:\nThis creates a potential dropped object once they cut the band or strap as they\ncan roll to the floor.\nThis also creates a potential hand and or finger injury as there are multiple pinch\npoints when stacking and unstacking\nThis also creates a potential back injury as the user is moving thousands of these\n\n<<<PAGE 6>>>\n\nweekly with average gun weighing 15-50 lbs. each\nTime it takes to physically unsecure each gun, move each gun to label, and then\nplace back on pallet and secure for transport .\nWhat Wellmatics solution to this is to extend the threaded end cap protector to\naccept the sticker so that the user can leave the gun bodies secured to the pallets\nonly have to move the charge tube or strip to load which is significantly lighter.\nThe threaded gun label end protector would allow the user to visibly show each\ngun has a sticker as these are not hidden in a stacked configuration.\nWhen an inspection occurs the inspector could identify immediately the label\non the threaded end cap and would not have to un secure the stacked gun\nbodies in the event they wanted to do a full inspection of each individual\nperforating gun.\nWhat interpretation Wellmatics is looking for is -Will the label sticker if\nplaced on the threaded end cap be considered compliant for individually\nlabeled jet perforating guns?\nThank you,\nJoshua Howk\n6770 McHard Road\n\n<<<PAGE 7>>>\n\nHouston, TX 77053\nWELLMATICS","truncated":false,"body_characters":6755}