Hunting Titan, Inc. — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Avenue, SE Washington, DC 20590 May 10, 2024 Joseph Murphy Compliance Manager Hunting Titan 16825 Northchase Drive Suite 600 Houston, TX 77060 Reference No. 23-0097 Dear Mr. Murphy: This letter is in response to your October 31, 2023, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers. Specifically, you request clarification on the requirement to indicate the type of packages on a shipping paper, in accordance with § 172.202(a)(7), as it relates to transporting jet perforating guns (JPGs), shipped under the proper shipping name “UN0494, Jet perforating guns, charged, 1.4D. ” You ask what the package type should be to describe “UN0494, Jet perforating guns, charged, 1.4D” on a shipping paper, in accordance with § 172.202(a)(7). Unless a specific packaging method has been prescribed by the Pipeline and Hazardous Materials Safety Administration (PHMSA) on an EX approval or applicable Department of Transportation (DOT) special permit, JPGs are typically transported unpackaged under the provisions of § 173.62, Packaging Instruction US1. Because your JPGs are transported as unpackaged articles, there is no packaging type to indicate on your shipping paper, as would otherwise be required under § 172.202(a)(7). Therefore, it is the opinion of this Office that for unpackaged articles described in this scenario, it is permitted to provide an accurate descriptor of the articles in lieu of a packaging type for the requirements of § 172.202(a)(7)—examples include “jet perforating guns, ” “JPGs,” or “explosive articles. ” I hope this information is helpful. Please contact us if we can be of further assistance. Sincerely, Steven Andrews Acting Chief, Regulatory Review and Reinvention Branch Standards and Rulemaking Division#

Page 2Jacobson 23-0097 From: INFOCNTR (PHMSA) To: Dodd, Alice (PHMSA) Cc: Hazmat Interps Subject: FW: Letter of Interpretation Request - Hunting Titan Date: Wednesday, November 1, 2023 11:04:04 AM Attachments: Hunting Titan Letter of Interpretation Request - 10-31-2023.pdf Hi Alice, Please see the attached interpretation request. Let us know if you need anything. Sincerely, Janaye From: Joe Murphy <Joe.Murphy@Hunting-intl.com> Sent: Tuesday, October 31, 2023 3:13 PM To: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov> Subject: Letter of Interpretation Request - Hunting Titan CAUTION: This email originated from outside of the Department of Transportation (DOT). Do not click on links or open attachments unless you recognize the sender and know the content is safe. To Whom it May Concern, Please see attached Letter of Interpretation request. If any further info is needed, please let me know. Thank you. Respectfully, Joseph Murphy Compliance Manager/Distribution HSE Hunting Titan, Inc. 16825 Northchase Dr. Suite 600 Houston, TX 77060 O: 281-214-4500 Ext. 4477 C: 346-302-1607 This E-Mail is confidential and may also be subject to legal privilege. If you are not the intended recipient, do not copy, forward or use this E-Mail for any purpose, nor disclose its contents to any other parties and notify us by return E-Mail. Warning Although this message has been checked for all known viruses using Anti-Virus Software, © 2017 (all rights reserved), Hunting cannot accept responsibility for any loss or damage arising from the use of this E-Mail or attachments. Information about the company can be found at www.huntingplc.com#

Page 3October 31, 2023 US Department of Transportation Pipeline and Hazardous Materials Safety Administration 1200 New Jersey Ave. SE Washington, DC 20590 Subject: Request of Letter of Interpretation Hunting Titan 16825 Northchase Drive, Suite 600 Houston, TX 77060 Office 281-448-2200 Fax 281-448-2227 www.hunting-intl.com To whom it may concern, Hunting Titan, Inc. respectfully requests an interpretation of 49CFR172.202(a)(7). The number and type of packages must be indicated. The type of packages must be indicated by description of the package (for example, “12 drums”). Indication of the packaging specification number (“1H1”) may be included in the description of the package (for example, “12 1H1 drums” or “12 drums (UN 1A1)”). Abbreviations may be used for indicating packaging types (for example, “cyl.” for “cylinder”) provided the abbreviations are commonly accepted and recognizable. Specifically, we ship and transport UN0494, Jet perforating guns, charged, 1.4D daily as part of our business. Question 1: What does PHMSA believe is the best “type” of package that should be listed in the number and type column? The jet perforating guns are various lengths of pipe containing shaped charges, detonator cord and boosters. We believe pipe is not an accurate reflection of the material and it is not your typical cylinder under gaseous pressure. Question 2: Could we call it a “jet perforating gun” and abbreviate it as JPG? Your consideration of this request is appreciated. Please let me know if additional information is needed. I may be contacted at 346-302-1607 or joe.murphy@hunting-intl.com. Respectfully, Joseph Murphy Joseph Murphy Compliance Manager#