Interpretation Response #10-0109 ([Mr. Scott A. Pilch])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name:
Individual Name: Mr. Scott A. Pilch
Location State: WY Country: US
View the Interpretation Document
Response text:
October 14, 2010
Mr. Scott A. Pilch
107 Mesa Drive
Evanston, WY 82930
Reference No. 10-0109
Dear Mr. Pilch:
This responds to your request for clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to jet perforating guns. Specifically, you ask the meaning of US 1 (1)(d)(i) following the § 173.62(c) Table of Packing Methods, which states in part:
A motor vehicle transporting a (perforating) gun must have specially built racks or carrying cases designed and constructed so that the gun is securely held in place during transportation and is not subject to damage by contact, one to the other or any other article or material carried in the vehicle;
You ask whether this paragraph means that: (1) perforating guns are to be transported and secured in a manner that will eliminate movement that would allow the perforating guns to contact (strike) other guns or articles in the load; or (2) perforating guns are to be transported and secured in a manner that does not allow them to contact (touch) other guns, i.e; the guns are not allowed to lay side-by-side so that they touch each other.
US 1 (1)(d)(i) means that the guns must be secured in place in specially built racks or carrying cases in a manner to prevent the guns from any contact (including touching) with other guns, as well as with other articles or materials, being transported in the vehicle that will cause damage to the perforating guns.
I hope this information is helpful. Please contact this office should you have additional questions.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
173..62(c)
Regulation Sections
| Section | Subject |
|---|---|
| 173.62 | Specific packaging requirements for explosives |