Interpretation Response #05-0033 ([Hazmat Seminars] [Mr. Paul Shelton])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date: 04/12/2005

Company Name: Hazmat Seminars

Individual Name: Mr. Paul Shelton

Location State: TN Country: US

View the Interpretation Document

Response text:

Apr 12, 2005

Mr. Paul Shelton                      Reference No. 05-0033
Hazmat Seminars
Post Office Box 6122
Oak Ridge, Tennessee 37831

Dear Mr. Shelton:

This responds to your January 26, 2005 letter requesting clarification of the packaging requirements for explosives contained in § 173.62 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if shippers are free to utilize any option provided in the referenced packing instruction for an explosive, assuming there is no packaging specified in the approval letter, even when that option differs from the configuration in which classification testing was conducted.

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 new 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. If the approval does not contain specific packaging requirements, the explosive must be packaged as prescribed in the Table of Packaging Methods found in § 173.62. In these instances, you may utilize any packaging configuration authorized by the packing instruction for the explosive.

I hope this information is helpful. Please contact us if you require additional assistance.

Sincerely,

John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards

173.62

Regulation Sections