Pratt & Whitney — Hazardous Materials Safety Interpretation

Page 1U.S. Department of Transportation Washington, D.C. 20590 400 Seventh Street, S.W Research and special Programs Administration JAN 1 3 1999 Ms. Jenny Hobby Ref. No. 98-0376 Pratt & Whitney Traffic Packaging Engineering 600 Metcalf Road San Jose, CA 95138 Dear Ms. Hobby: This is in response to your letter of December 11, 1998 concerning the segregation of explosives under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically you were inquiring about the rules for transporting Division 1.4B and 1.2B explosives with Division • 1.4S detonators. Section 177.848 contains the Compatibility Table for Class 1 (Explosive) materials. Note four is indicated when considering Group B and S materials which refers to § 177.835. »Section 177.835 (g) prohibits the transportation of detonators on the same motor vehicle with any Division 1.1, 1.2, or 1.3 (Class A or Class B) material (except other detonator assemblies, boosters with detonators or other detonators), explosives for blasting, or detonating cord Division 1.4 (Class C) material. These materials may be transported on the same motor vehicle only if the requirements of § 177.835 (g) (1), (2), and (3) are met. We also wish to clarify the difference between a transport vehicle and a motor vehicle, as this issue was raised in telephone conversations with members of our staff. As defined in § 171.8, a transport vehicle means a cargo-carrying vehicle and each cargo-carrying body is a separate transport vehicle. !,7835#

Page 2: A motor vehicle is defined as any number of transport vehicles powered by the same motor or engine (except vehicles which travel by rail or a trolley). I hope this satisfies your request. Sincerely, Transportation Regulations Specialist Office of Hazardous Materials Standards#

Page 3of Transportation U.S. Department Washington, D.C. 400 Seventh Street, S.W. • 20590 Research and Special Programs Administration JAN 1 3 1999 Ms. Jenny Hobby Pratt & Whitney Ref. No. 98-0376 Traffic Packaging Engineering 600 Metcalf Road Jose, CA 95138 Dear Ms. Hobby: This is in response to your letter of December 11, 1998 concerning the segregation of explosives under the Hazardous Materials Regulations Specifically you were inquiring about the rules for (HMR; 49 CER Parts 171-180). transporting Division 1.4B and 1.2B explosives with Division 1:4S detonators. Section 177.848 contains the Compatibility Table for Class 1 (Explosive) materials. Note four is indicated when considering Group B and S materials which refers to § 177.835. Section 177.835 (g) prohibits the transportation of detonators on the same motor vehicle with any Division 1.1, 1.2, or 1.3 (Class A or Class B) material (except other detonator assemblies, boosters with detonators or other detonators), explosives for blasting, or detonating cord Division 1.4 (Class C) material. These materials may be transported on the same motor vehicle only if the requirements of $ 177.835 (g) (1), (2), and (3) are met. we also wish to clarify the difference between a transport vehicle and a motor vehicle, as this issue was raised in telephone conversations with members of our staff. As defined In S 111.0, a transport vehicle means a cargo-carrying vehicle and each cargo-carrying body is a separate transport vehicle. 177.835#

Page 4A motor vehicle is defined as any number of transport vehicles powered by the same motor or engine (except vehicles which travel by rail or a trolley). I hope this satisfies your request. Sincerely, bones Transportation Regulations Specialist Office of Hazardous Materials Standards#

Page 5DEC 1Ï 198. 01:48PMUTC/CSD TRAFFIC P.1 Chemical Syslems P.O. Box 49028 San Jose, CA 95161.9028 Pratt & Whitney A United Technologles Company BAH 5177.834 FAX COVER SHEET 1 98-0376 Date: 12/11/48 Number of Page: * Io: DiAne Lavalle/mixe Johnson Company: Do T Fax Number: 202 364-3012 Remarks: Ranger TransporTATIon 5A1s it was Legal to put ClASS 1.45 in a Tractor drone a put 14+128 in the trailer (vant of the same truck The 145 are detonators. A Rangee representative sars he spoke to you I you approved, would leonfirm this for me, please. from 49 CFR seems to contradict this 172.8359 Considerig the 145 are detonATORs. Thanks! Jenny oly, affitPackaging Engineering 600 Metcalf Road, San Jose, CA 95138 STIU NEEDS Phone: (408) 776-4219/Fax -776-4822 E-Mail: Hobby@CSD.com LETTER#

Page 6§ 177.835 49 CFR Ch. 1 (10-98 Edition) 6.1 (poisonous) materials, or (il) Division 2.3 (poisonous gas) or Division ter, and its use is restricted to instances ments prescribed in § 173.63 of this subchap- (2) The package conforms with require- or a DOT specification 106A or 110A tank. (iv) Hazardous materials in a portable tank when- (e) No sharp projections inside body of vehi- (d) [Reserved) A or Class B explosive) material or blasting (i) There is no Division 1.1, 1.2, or 1.3 (Class cles. No motor vehicle transporting any kind agent loaded on the motor vehicle; and of Class 1 (explosive) material shall have on maintained between each package of detona- (ii) A separation of 61 cm (24 inches) is (explosive) materials are contained, any in- the interior of the body in which the Class 1 tors and each package of detonating cord; or wardly projecting bolts, screws, nails, or other with a method approved by the Department. (3) It is packed and loaded in accordance inwardly projecting parts likely to produce (explosive) materials during the loading or damage to any package or container of Class 1 as follows: One method approved by the Department is unloading process or in transit. scribed in § 173.63 of this subchapter which in (i) The detonators are in packagings as pre- floors tight and lined. Motor vehicles trans- (f) Class 1 (explosive) materials vehicles, separate compartments. Both the detonators turn are loaded into suitable containers or porting Division 1.1, 1.2, or 1.3 (Class A or Class B explosive) materials shall have tight the requirements of the Institute of Makers of and the container or compartment must meet in contact with the load lined with either non- floors; shall have that portion of the interior Explosives' Standard (IME Safety Library cept that the lining is not required for truck metallic material or non-ferrous metals, ex- Publication No. 22). closed. Except as provided in paragraphs (g), (h) Lading within body or covered tailgate load shipments loaded by the Departments of the Army, Navy or Air Force of the United (k), and (m) of this section, dealing with the States Government provided the Class 1 (ex- transportation of liquid nitroglycerin, desen- plosive) materials are of such nature that they sitized liquid nitroglycerin or diethylene gly- vapor which might become the cause of an ex- are not liable to leakage of dust, powder, or any motor vehicle which consists of Class 1 col dinitrate, all of that portion of the lading of plosion. The interior of the cargo space must (explosive) materials shall be contained en- be in good condition so that there will not be tirely within the body of the motor vehicle or any likelihood of containers being damaged by overhang or projection of any part of the load within the horizontal outline thereof, without foor boards, or any similar projections. exposed bolts, nuts, broken side panels or and if such motor vehicle has a tailboard or detonator may be transported on the same - (g) No detonator assembly or booster with tailgate, it shall be closed and secured in place during such transportation. Every motor ve- motor vehicle with any Division 1.1, 1.2 or 1.3 als must either have a closed body or have the hicle transporting Class 1 (explosive) materi- cept other detonator assemblies, boosters Class A or Class B explosive) material (ex- body thereof covered with a tarpaulin, and in blasting or detonating cord Division 1.4 (Class with detonators or detonators), explosives for either event care must be taken to protect the subject to other provisions of these regula- load from moisture and sparks, except that transported on the same motor vehicle with C explosive) material. No detonator may be tions, Class 1 (explosive) materials other than any Division 1.1, 1.2 or 1.3 (Class A or Class B explosive) material (except other detonators, detonator assemblies or boosters with detona- tors), explosives for blasting or detonating ord Division 1.4 (Class C explosive) material ter resistant tarpaulin. unless- (i) Class 1 (explosive) materials to be pro (§ 178.318 of this subchapter) container; or (1) It is packed in a specification MC 201 tected against damage by other lading. No mo- tor vehicle transporting any Class 1 800#

Page 7§ 177.854 49 CFR Ch. 1 (10-98 Edition) table for Class 1 (explosive) materials are as (g) Instructions for using the compatibility follows: FR 49134, Sept. 26, 1994; Amdt. 177-87, 61 FR 27175, May 30, 1996] that no restrictions apply. (1) A blank space in the Table indicates Subpart D-Vehicles and Shipments in explosives of different compatibility groups (2) The letter "X" in the Table indicates that Transit; Accidents hicle. may not be carried on the same transport ve- $177.854 Disabled vehicles and broken (a) Care of lading, hazardous materials. or leaking packages; repairs. (3) The numbers in the Table mean the fol- traffic stops any motor vehicle transporting Whenever for any cause other than necessary ity group L shall only be carried on the same (i) "1" means an explosive from compatibil- traveled portion of any highway or shoulder any hazardous material is stopped upon the ransport vehicle with an identical explosive from compatibility groups C, D, or E is as- il) "2" means any combination of explosive the vehicle and its load or to take such steps thereof, special care shall be taken to guard signed to compatibility group E. as may be necessary to provide against haz- sives from compatibility groups C, D, or E (iii) 43" means any combination of explo- ard. Special effort shall be made to remove the the materials being transported may be pro- motor vehicle to a place where the hazards of 848 signed to compatibility group D. with those in compatibility group N is as- 392.25 of this title for warning devices re- vided against. See §§ 392.22, 392.24, and ing detonators. (iv) "4" means § 177.835(g) when transport- quired to be displayed on the highway. not be loaded on the same transport vehicle (v) "5" means Division 1.4S fireworks may or leaking in transit. When leaks occur in (b) Disposition of containers found broken materials. with Division 1.1 or 1.2 (Class A explosive) packages or containers during the course of disposition of such package or container shall transportation, subsequent to initial loading, this section, explosives of the same compati- (h) Except as provided in paragraph (i) of be made by the safest practical means afford- bility group but of different divisions may be section. ed under paragraphs (c), (d), and (e) of this transported together provided that the whole shipment is transported as though its entire Packages may be repaired when safe and (c) Repairing or overpacking packages. (1) (i.e., Division 1.1 being lower than Division contents were of the lower numerical division with the best and safest practice known and practicable, such repairing to be in accordance 1.2). For example, a mixed shipment of Divi- vision 1.4 (Class C explosive) materials, both sion 1.2 (Class A explosive) materials and Di- available. are damaged or found leaking during trans- (2) Packages of hazardous materials that of compatibility group D, must be transported as Division 1.2 (Class A explosive) materials. spilled or leaked during transportation, may portation, and hazardous materials that have rials, compatibility group D, are transported (i) When Division 1.5 (blasting agent) mate- be forwarded to destination or returned to the the requirements of § 173.3(c) of this subchap- shipper in a salvage drum in accordance with group D, the shipment must be transported as Dipion tity group D. explosive) materiale, Amdt. 177-78, 55 FR 52712, Dec, 21, 1990, as mended at 56 FR 66283, Dec. 20, 1991; 57 FI 812#