Interpretation Response #09-0022 ([NASA Wallops Flight Facility] [Mr. Ernest Cornwell])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: NASA Wallops Flight Facility
Individual Name: Mr. Ernest Cornwell
Location State: VA Country: US
View the Interpretation Document
Response text:
April 10, 2009
Mr. Ernest Cornwell
NASA Wallops Flight Facility
32400 Fulton Street, Building M-16 Room 107
Wallops Island, VA 23337
Ref. No.: 09-0022
Dear Mr. Cornwell:
This is in response to your letter dated January 23, 2009 requesting clarification of the Hazardous Material Regulations (HMR; 49 CFR Parts 171-180) applicable to the classification of explosives. In your letter you describe a parachute recovery system that uses reefing line cutters classed and approved by the Department of Transportation (DOT) as "Cutters, cable, explosive, 1.4S, UN0070." You ask if a reefing line cutter packed in the parachute recovery system may also be described as "Cutters, cable, explosive, UN0070, 1.4S."
The answer is no. A parachute recovery system with a previously approved reefing line cutter installed would be considered a new explosive under § 173.56 and must be classed by DOT. In accordance with § 173.56, a person requesting approval of a new explosive must submit to the Associate Administrator a report of the examination and assignment of a recommended shipping description, division, and compatibility group. If the Associate Administrator finds the approval request meets the regulatory criteria, the new explosive will be approved in writing and assigned an EX number. The Office of Hazardous Materials Approvals may be reached by telephone at (202) 366-4511.
I trust this satisfies your inquiry. If we can be of further assistance, please contact us.
Sincerely,
Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards
173.53