Interpretation Response #10-0052 ([Alliant Techsystems Inc. (ATK)] [Mr. Christopher J. Widman])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Alliant Techsystems Inc. (ATK)
Individual Name: Mr. Christopher J. Widman
Location State: MN Country: US
View the Interpretation Document
Response text:
October 4, 2011
Mr. Christopher J. Widman
Corporate DOT Haz Mat
Transportation Specialist
Alliant Techsystems Inc. (ATK)
7480 Flying Cloud Drive
Minneapolis, MN 55344-3720
Ref. No. 10-0052
Dear Mr. Widman:
This responds to your letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the requirements for testing and packaging large and robust explosive articles. Specifically, you ask two questions regarding the responsibility for ensuring Series 4 tests are successfully accomplished for unpackaged explosive articles prescribed in Packing Method 130 of § 173.62. Your questions are paraphrased and answered as follows.
Q1. Packing Method 130 of § 173.62 authorizes certain large and robust explosive articles to be shipped unpackaged if a negative result is achieved when Test Series 4 in the UN Manual of Tests and Criteria is conducted on the article. Must Test Series 4 be successfully conducted prior to offering for transportation or transporting an unpackaged article under § 173.62(c)(5) Packing Method 130?
A1. No. Test Series 4 may be waived at the discretion of the examining laboratory with sufficient justification or by PHMSA where impractical.
Q2. Is it the shipper"s responsibility to ensure that Test Series 4 is conducted on an unpackaged explosive article, if appropriate? If not, whose responsibility is it?
A2. The shipper must determine whether or not the examining laboratory will require the test in order to complete its evaluation of the unpackaged article.
In accordance with § 173.56(b)(1), the person requesting approval for the explosive must submit a report of test results and assignment of a recommended shipping description, division, and compatibility group. Subsequent offerors must obtain a separate approval for any packaging deviations made before shipment.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
173.62, 173.56
Regulation Sections
| Section | Subject |
|---|---|
| 173.62 | Specific packaging requirements for explosives |