{"operation":"document","citation":"23-0097","title":"Hunting Titan, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2024-05-10","effective_on":null,"summary":"23-0097 response to Hunting Titan, Inc. concerning 172.202, 173.62.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-23-0097.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-23-0097.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-23-0097","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2024-05/230097.pdf","body":"<<>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nMay 10, 2024\nJoseph Murphy\nCompliance Manager\nHunting Titan\n16825 Northchase Drive\nSuite 600\nHouston, TX 77060\nReference No. 23-0097\nDear Mr. Murphy:\nThis letter is in response to your October 31, 2023, letter requesting clarification of the\nHazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers.\nSpecifically, you request clarification on the requirement to indicate the type of packages on a\nshipping paper, in accordance with § 172.202(a)(7), as it relates to transporting jet perforating\nguns (JPGs), shipped under the proper shipping name “UN0494, Jet perforating guns, charged,\n1.4D.\n” You ask what the package type should be to describe “UN0494, Jet perforating guns,\ncharged, 1.4D” on a shipping paper, in accordance with § 172.202(a)(7).\nUnless a specific packaging method has been prescribed by the Pipeline and Hazardous\nMaterials Safety Administration (PHMSA) on an EX approval or applicable Department of\nTransportation (DOT) special permit, JPGs are typically transported unpackaged under the\nprovisions of § 173.62, Packaging Instruction US1. Because your JPGs are transported as\nunpackaged articles, there is no packaging type to indicate on your shipping paper, as would\notherwise be required under § 172.202(a)(7). Therefore, it is the opinion of this Office that for\nunpackaged articles described in this scenario, it is permitted to provide an accurate descriptor of\nthe articles in lieu of a packaging type for the requirements of § 172.202(a)(7)—examples\ninclude “jet perforating guns,\n” “JPGs,” or “explosive articles.\n”\nI hope this information is helpful. Please contact us if we can be of further assistance.\nSincerely,\nSteven Andrews\nActing Chief, Regulatory Review and Reinvention Branch\nStandards and Rulemaking Division\n\n<<>>\n\nJacobson\n23-0097\nFrom: INFOCNTR (PHMSA)\nTo: Dodd, Alice (PHMSA)\nCc: Hazmat Interps\nSubject: FW: Letter of Interpretation Request - Hunting Titan\nDate: Wednesday, November 1, 2023 11:04:04 AM\nAttachments: Hunting Titan Letter of Interpretation Request - 10-31-2023.pdf\nHi Alice,\nPlease see the attached interpretation request. Let us know if you need anything.\nSincerely,\nJanaye\nFrom: Joe Murphy \nSent: Tuesday, October 31, 2023 3:13 PM\nTo: INFOCNTR (PHMSA) \nSubject: Letter of Interpretation Request - Hunting Titan\nCAUTION: This email originated from outside of the Department of Transportation (DOT). Do\nnot click on links or open attachments unless you recognize the sender and know the content\nis safe.\nTo Whom it May Concern,\nPlease see attached Letter of Interpretation request. If any further info is needed, please let me\nknow. Thank you.\nRespectfully,\nJoseph Murphy\nCompliance Manager/Distribution HSE\nHunting Titan, Inc.\n16825 Northchase Dr.\nSuite 600\nHouston, TX 77060\nO: 281-214-4500 Ext. 4477 C: 346-302-1607\nThis E-Mail is confidential and may also be subject to legal privilege. If you are not the intended\nrecipient, do not copy, forward or use this E-Mail for any purpose, nor disclose its contents to any\nother parties and notify us by return E-Mail. Warning Although this message has been checked for all\nknown viruses using Anti-Virus Software, © 2017 (all rights reserved), Hunting cannot accept\nresponsibility for any loss or damage arising from the use of this E-Mail or attachments. Information\nabout the company can be found at www.huntingplc.com\n\n<<>>\n\nOctober 31, 2023\nUS Department of Transportation\nPipeline and Hazardous Materials Safety Administration\n1200 New Jersey Ave. SE\nWashington, DC 20590\nSubject: Request of Letter of Interpretation\nHunting Titan\n16825 Northchase Drive, Suite 600\nHouston, TX 77060\nOffice 281-448-2200\nFax 281-448-2227\nwww.hunting-intl.com\nTo whom it may concern,\nHunting Titan, Inc. respectfully requests an interpretation of 49CFR172.202(a)(7).\nThe number and type of packages must be indicated. The type of packages must be\nindicated by description of the package (for example, “12 drums”). Indication of the\npackaging specification number (“1H1”) may be included in the description of the\npackage (for example, “12 1H1 drums” or “12 drums (UN 1A1)”). Abbreviations may\nbe used for indicating packaging types (for example, “cyl.” for “cylinder”) provided\nthe abbreviations are commonly accepted and recognizable.\nSpecifically, we ship and transport UN0494, Jet perforating guns, charged, 1.4D daily as part of\nour business.\nQuestion 1: What does PHMSA believe is the best “type” of package that should be listed in the\nnumber and type column? The jet perforating guns are various lengths of pipe containing shaped\ncharges, detonator cord and boosters. We believe pipe is not an accurate reflection of the\nmaterial and it is not your typical cylinder under gaseous pressure.\nQuestion 2: Could we call it a “jet perforating gun” and abbreviate it as JPG?\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","truncated":false,"body_characters":5262}