{"operation":"document","citation":"98-0376","title":"Pratt &amp; Whitney — Hazardous Materials Safety Interpretation","source_type":"guidance","agency":"Pipeline and Hazardous Materials Safety Administration","status":"guidance","official":true,"published_on":"1999-01-13","effective_on":null,"summary":"98-0376 response to Pratt &amp; Whitney concerning 177.835.","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0376.json","markdown":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0376.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-interpretation-98-0376","source_url":"https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/legacy/interpretations/Interpretation%20Files/1998/980376.pdf","body":"<<<PAGE 1>>>\n\nU.S. Department\nof Transportation\nWashington, D.C. 20590\n400 Seventh Street, S.W\nResearch and\nspecial Programs\nAdministration\nJAN 1 3 1999\nMs. Jenny Hobby\nRef. No. 98-0376\nPratt & Whitney\nTraffic Packaging Engineering\n600 Metcalf Road\nSan Jose, CA 95138\nDear Ms. Hobby:\nThis is in response to your letter of December 11, 1998\nconcerning the segregation of explosives under the Hazardous\nMaterials Regulations (HMR; 49 CFR Parts 171-180).\nSpecifically you were inquiring about the rules for\ntransporting Division 1.4B and 1.2B explosives with Division\n• 1.4S detonators.\nSection 177.848 contains the Compatibility Table for Class 1\n(Explosive) materials.\nNote four is indicated when\nconsidering Group B and S materials which refers to § 177.835.\n»Section 177.835 (g) prohibits the transportation of detonators\non the same motor vehicle with any Division 1.1, 1.2, or 1.3\n(Class A\nor Class B) material (except other detonator\nassemblies, boosters with detonators or other detonators),\nexplosives for blasting, or detonating cord Division 1.4\n(Class C) material.\nThese materials may be transported on the\nsame motor vehicle only if the requirements of\n§ 177.835 (g) (1), (2), and (3) are met.\nWe also wish to clarify the difference between a\ntransport\nvehicle and a motor vehicle, as this issue was raised in\ntelephone conversations with\nmembers of our staff.\nAs defined\nin § 171.8, a transport vehicle means a cargo-carrying vehicle\nand each\ncargo-carrying body is\na separate transport vehicle.\n!,7835\n\n<<<PAGE 2>>>\n\n:\nA motor vehicle is defined as any number of transport vehicles\npowered by the same motor or engine (except vehicles which\ntravel by rail or a trolley).\nI hope this satisfies your request.\nSincerely,\nTransportation Regulations Specialist\nOffice of Hazardous Materials Standards\n\n<<<PAGE 3>>>\n\nof Transportation\nU.S. Department\nWashington, D.C.\n400 Seventh Street, S.W. •\n20590\nResearch and\nSpecial Programs\nAdministration\nJAN 1 3 1999\nMs. Jenny Hobby\nPratt & Whitney\nRef. No. 98-0376\nTraffic Packaging Engineering\n600 Metcalf Road\nJose, CA 95138\nDear Ms. Hobby:\nThis is in response to your letter of December 11, 1998\nconcerning the segregation of explosives under the Hazardous\nMaterials Regulations\nSpecifically you were inquiring about the rules for\n(HMR; 49 CER Parts 171-180).\ntransporting Division 1.4B and 1.2B explosives with Division\n1:4S detonators.\nSection 177.848 contains the Compatibility Table for Class 1\n(Explosive)\nmaterials.\nNote four is indicated when\nconsidering Group B and S materials which refers to § 177.835.\nSection 177.835 (g) prohibits the transportation of detonators\non the same motor vehicle with any Division 1.1, 1.2, or 1.3\n(Class A or Class B) material (except other detonator\nassemblies, boosters with detonators or other detonators),\nexplosives for blasting, or detonating cord Division 1.4\n(Class C) material. These materials may be transported on the\nsame motor vehicle only if the requirements of\n$ 177.835 (g) (1), (2), and (3) are met.\nwe also wish to clarify the difference between a transport\nvehicle and a motor vehicle, as this issue was raised in\ntelephone conversations with members of our staff. As defined\nIn S 111.0, a transport vehicle means a cargo-carrying vehicle\nand each\ncargo-carrying body is a separate transport vehicle.\n177.835\n\n<<<PAGE 4>>>\n\nA motor vehicle is defined as any number of transport vehicles\npowered by the same motor or engine (except vehicles which\ntravel by rail or a trolley).\nI hope this satisfies your request.\nSincerely,\nbones\nTransportation Regulations Specialist\nOffice of Hazardous Materials Standards\n\n<<<PAGE 5>>>\n\nDEC 1Ï 198. 01:48PMUTC/CSD TRAFFIC\nP.1\nChemical Syslems\nP.O. Box 49028\nSan Jose, CA 95161.9028\nPratt & Whitney\nA United Technologles Company\nBAH\n5177.834\nFAX COVER SHEET\n1 98-0376\nDate: 12/11/48\nNumber of Page: *\nIo: DiAne Lavalle/mixe Johnson\nCompany: Do T\nFax Number:\n202 364-3012\nRemarks: Ranger TransporTATIon 5A1s it was\nLegal to put ClASS 1.45 in a Tractor drone\na put 14+128 in the trailer (vant of the\nsame truck\nThe 145 are detonators.\nA Rangee representative sars he spoke to you\nI you approved, would leonfirm this for me, please.\nfrom 49 CFR seems to contradict this\n172.8359\nConsiderig\nthe\n145 are detonATORs.\nThanks!\nJenny oly, affitPackaging Engineering\n600 Metcalf Road, San Jose, CA 95138\nSTIU NEEDS\nPhone: (408) 776-4219/Fax -776-4822\nE-Mail: Hobby@CSD.com\nLETTER\n\n<<<PAGE 6>>>\n\n§ 177.835\n49 CFR Ch. 1 (10-98 Edition)\n6.1 (poisonous) materials, or\n(il) Division 2.3 (poisonous gas) or Division\nter, and its use is restricted to instances\nments prescribed in § 173.63 of this subchap-\n(2) The package conforms with require-\nor a DOT specification 106A or 110A tank.\n(iv) Hazardous materials in a portable tank\nwhen-\n(e) No sharp projections inside body of vehi-\n(d) [Reserved)\nA or Class B explosive) material or blasting\n(i) There is no Division 1.1, 1.2, or 1.3 (Class\ncles. No motor vehicle transporting any kind\nagent loaded on the motor vehicle; and\nof Class 1 (explosive) material shall have on\nmaintained between each package of detona-\n(ii) A separation of 61 cm (24 inches) is\n(explosive) materials are contained, any in-\nthe interior of the body in which the Class 1\ntors and each package of detonating cord; or\nwardly projecting bolts, screws, nails, or other\nwith a method approved by the Department.\n(3) It is packed and loaded in accordance\ninwardly projecting parts likely to produce\n(explosive) materials during the loading or\ndamage to any package or container of Class 1\nas follows:\nOne method approved by the Department is\nunloading process or in transit.\nscribed in § 173.63 of this subchapter which in\n(i) The detonators are in packagings as pre-\nfloors tight and lined. Motor vehicles trans-\n(f) Class 1 (explosive) materials vehicles,\nseparate compartments. Both the detonators\nturn are loaded into suitable containers or\nporting Division 1.1, 1.2, or 1.3 (Class A or\nClass B explosive) materials shall have tight\nthe requirements of the Institute of Makers of\nand the container or compartment must meet\nin contact with the load lined with either non-\nfloors; shall have that portion of the interior\nExplosives' Standard (IME Safety Library\ncept that the lining is not required for truck\nmetallic material or non-ferrous metals, ex-\nPublication No. 22).\nclosed. Except as provided in paragraphs (g),\n(h) Lading within body or covered tailgate\nload shipments loaded by the Departments of\nthe Army, Navy or Air Force of the United\n(k), and (m) of this section, dealing with the\nStates Government provided the Class 1 (ex-\ntransportation of liquid nitroglycerin, desen-\nplosive) materials are of such nature that they\nsitized liquid nitroglycerin or diethylene gly-\nvapor which might become the cause of an ex-\nare not liable to leakage of dust, powder, or\nany motor vehicle which consists of Class 1\ncol dinitrate, all of that portion of the lading of\nplosion. The interior of the cargo space must\n(explosive) materials shall be contained en-\nbe in good condition so that there will not be\ntirely within the body of the motor vehicle or\nany likelihood of containers being damaged by\noverhang or projection of any part of the load\nwithin the horizontal outline thereof, without\nfoor boards, or any similar projections.\nexposed bolts, nuts, broken side panels or\nand if such motor vehicle has a tailboard or\ndetonator may be transported on the same\n- (g) No detonator assembly or booster with\ntailgate, it shall be closed and secured in place\nduring such transportation. Every motor ve-\nmotor vehicle with any Division 1.1, 1.2 or 1.3\nals must either have a closed body or have the\nhicle transporting Class 1 (explosive) materi-\ncept other detonator assemblies, boosters\nClass A or Class B explosive) material (ex-\nbody thereof covered with a tarpaulin, and in\nblasting or detonating cord Division 1.4 (Class\nwith detonators or detonators), explosives for\neither event care must be taken to protect the\nsubject to other provisions of these regula-\nload from moisture and sparks, except that\ntransported on the same motor vehicle with\nC explosive) material. No detonator may be\ntions, Class 1 (explosive) materials other than\nany Division 1.1, 1.2 or 1.3 (Class A or Class B\nexplosive) material (except other detonators,\ndetonator assemblies or boosters with detona-\ntors), explosives for blasting or detonating\nord Division 1.4 (Class C explosive) material\nter resistant tarpaulin.\nunless-\n(i) Class 1 (explosive) materials to be pro\n(§ 178.318 of this subchapter) container; or\n(1) It is packed in a specification MC 201\ntected against damage by other lading. No mo-\ntor vehicle transporting any Class 1\n800\n\n<<<PAGE 7>>>\n\n§ 177.854\n49 CFR Ch. 1 (10-98 Edition)\ntable for Class 1 (explosive) materials are as\n(g) Instructions for using the compatibility\nfollows:\nFR 49134, Sept. 26, 1994; Amdt. 177-87, 61 FR\n27175, May 30, 1996]\nthat no restrictions apply.\n(1) A blank space in the Table indicates\nSubpart D-Vehicles and Shipments in\nexplosives of different compatibility groups\n(2) The letter \"X\" in the Table indicates that\nTransit; Accidents\nhicle.\nmay not be carried on the same transport ve-\n$177.854 Disabled vehicles and broken\n(a) Care of lading, hazardous materials.\nor leaking packages; repairs.\n(3) The numbers in the Table mean the fol-\ntraffic stops any motor vehicle transporting\nWhenever for any cause other than necessary\nity group L shall only be carried on the same\n(i) \"1\" means an explosive from compatibil-\ntraveled portion of any highway or shoulder\nany hazardous material is stopped upon the\nransport vehicle with an identical explosive\nfrom compatibility groups C, D, or E is as-\nil) \"2\" means any combination of explosive\nthe vehicle and its load or to take such steps\nthereof, special care shall be taken to guard\nsigned to compatibility group E.\nas may be necessary to provide against haz-\nsives from compatibility groups C, D, or E\n(iii) 43\" means any combination of explo-\nard. Special effort shall be made to remove the\nthe materials being transported may be pro-\nmotor vehicle to a place where the hazards of\n848\nsigned to compatibility group D.\nwith those in compatibility group N is as-\n392.25 of this title for warning devices re-\nvided against. See §§ 392.22, 392.24, and\ning detonators.\n(iv) \"4\" means § 177.835(g) when transport-\nquired to be displayed on the highway.\nnot be loaded on the same transport vehicle\n(v) \"5\" means Division 1.4S fireworks may\nor leaking in transit. When leaks occur in\n(b) Disposition of containers found broken\nmaterials.\nwith Division 1.1 or 1.2 (Class A explosive)\npackages or containers during the course of\ndisposition of such package or container shall\ntransportation, subsequent to initial loading,\nthis section, explosives of the same compati-\n(h) Except as provided in paragraph (i) of\nbe made by the safest practical means afford-\nbility group but of different divisions may be\nsection.\ned under paragraphs (c), (d), and (e) of this\ntransported together provided that the whole\nshipment is transported as though its entire\nPackages may be repaired when safe and\n(c) Repairing or overpacking packages. (1)\n(i.e., Division 1.1 being lower than Division\ncontents were of the lower numerical division\nwith the best and safest practice known and\npracticable, such repairing to be in accordance\n1.2). For example, a mixed shipment of Divi-\nvision 1.4 (Class C explosive) materials, both\nsion 1.2 (Class A explosive) materials and Di-\navailable.\nare damaged or found leaking during trans-\n(2) Packages of hazardous materials that\nof compatibility group D, must be transported\nas Division 1.2 (Class A explosive) materials.\nspilled or leaked during transportation, may\nportation, and hazardous materials that have\nrials, compatibility group D, are transported\n(i) When Division 1.5 (blasting agent) mate-\nbe forwarded to destination or returned to the\nthe requirements of § 173.3(c) of this subchap-\nshipper in a salvage drum in accordance with\ngroup D, the shipment must be transported as\nDipion tity group D. explosive) materiale,\nAmdt. 177-78, 55 FR 52712, Dec, 21, 1990, as\nmended at 56 FR 66283, Dec. 20, 1991; 57 FI\n812","truncated":false,"body_characters":12164}