Interpretation Response #16-0205 ([W. T Bell International Inc.] [James Rairigh])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: W. T Bell International Inc.
Individual Name: James Rairigh
Location State: TX Country: US
View the Interpretation Document
Response text:
April 13, 2017
James G. Rairigh
Vice President
W. T. Bell International, Inc.
8811 Emmott, #1900
Houston, TX 77040
Reference No. 16-0205
Dear Mr. Rairigh:
This letter is in response to your December 22, 2016, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to packaging requirements for explosives. You provide a scenario where an approval, EX 2013040288, classifies certain radial shaped charges as UN0440 when packaged in accordance with the approval. Packing instruction 137 is assigned to UN0440 in § 173.62, and it requires an orientation mark for conical shaped charges. Specifically, you seek confirmation of your understanding that the packaging description in EX 2013040288 takes precedence over the requirements in § 173.62.
The answer is yes. The competent authority approval issued by the Associate Administrator for Hazardous Materials Safety is the definitive statement of proper shipping name, identification number, and classification code for explosives. The approval document may also contain additional stipulations, including packaging requirements. Any packaging information contained in the approval document takes precedence over the requirements contained in the Table of Packing Methods in § 173.62. Therefore, radial shaped charges transported under EX 2013040288 must be packaged in accordance with the methods specified in this approval and are not subject to packing instruction 137 in § 173.62.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
Regulation Sections
| Section | Subject |
|---|---|
| 173.62 | Specific packaging requirements for explosives |