{"operation":"document","citation":"24-0095","title":"Chemring Energetic Devices, Inc. — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"2025-04-02","effective_on":null,"summary":"24-0095 response to Chemring Energetic Devices, Inc. concerning 173.56.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-24-0095.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-24-0095.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-24-0095","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/2025-04/240095.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nPipeline and Hazardous\nMaterials Safety\nAdministration\nApril 2, 2025\n1200 New Jersey Avenue, SE\nWashington, DC 20590\nEric Breeze\nManager of Project Management\nChemring Energetic Devices, Inc.\n2525 Curtiss Street\nDowners Grove, IL 60515\nReference No. 24-0095\nDear Mr. Breeze:\nThis letter is in response to your October 16, 2024 phone call and subsequent email requesting\nclarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable\nto explosives packaging requirements—specifically—packaging prescribed under an EX-\napproval. For an approved explosive, you ask whether adding desiccant bags and humidity\nindicator cards to the interior of the sealed plastic bag (i.e., the inner packaging) affects the\nclassification of the explosive article and whether it needs to be explicitly stated in a packaging\nnote.\nNo. A new explosive is an explosive produced by a person who has not previously produced\nthat explosive or has made a change in the formulation, design, or process to alter any of the\nproperties of the explosive—see § 173.56(a). It is the opinion of this Office that including\ndesiccant bags and/or humidity indicator cards in the packaging with the article are methods by\nwhich a manufacturer can ensure quality control of their products, and do not affect\nclassification of the article provided that their placement does not interfere with any mitigating\nfeatures of prescribed packaging. Therefore, adding them to a packaging used for transport does\nnot necessitate modifying the packaging note of the existing approval to include reference to use\nof desiccant bags or humidity indicator cards.\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 2>>>\n\nRoundtree\n24-0095\nFrom: INFOCNTR (PHMSA)\nTo: Dodd, Alice (PHMSA)\nCc: Hazmat Interps\nSubject: FW: Interpretation Request\nDate: Wednesday, October 16, 2024 4:46:48 PM\nAttachments: image001.png\nEX Approval_201822134.pdf\nHello Alice,\nPlease see the below interpretation request. Let us know if you need anything.\nSincerely,\nJanaye\nFrom: Eric Breeze <ebreeze@CED.US.COM>\nSent: Wednesday, October 16, 2024 4:08 PM\nTo: INFOCNTR (PHMSA) <INFOCNTR.INFOCNTR@dot.gov>\nSubject: Interpretation Request\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 this may concern,\nThis attached hazard classification calls out the packaging in the Notes section. My customer has\nrequested that we add desiccant and humidity indicator cards to the packaging, both of which are\nfully inert packing supplies.\nJonathan from hazmat info center stated that this addition would not have an impact on the hazard\nclass like I expected. He did state that if I wanted a formal answer, to request a letter of\ninterpretation which I would like to proceed with.\nTherefore can you please confirm adding these inert supplies to the packaging would not invalidate\nthe shipping classification? I have not accepted my customers request until I confirm I would still be\nable to ship per EX2018022134. The box size and QTY would stay the same. There is empty space\navailable to add desiccant and humidity indicator card.\nYour assistance on this issue is greatly appreciated. Thank you in advance.\nEric Breeze\nManager of Project Management\nChemring Energetic Devices, Inc.\n2525 Curtiss Street | Downers Grove, IL 60515\nD: (630) 981-8388 | C: (331) 201-7445\nE: ebreeze@ced.us.com\n\n<<<PAGE 3>>>\n\nNOTICE: This electronic communication, (including any attachments) is intended\nexclusively for the individuals or entities to which it is addressed. It may contain\nsensitive, restricted, or proprietary information. Any unauthorized disclosure, use,\ndissemination, or copying is strictly prohibited and may be unlawful. If you have\nreceived this communication in error, please notify its sender immediately by replying\nand then permanently delete this communication from your IT system.","truncated":false,"body_characters":4170}