Interpretation Response #24-0095
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Chemring Energetic Devices, Inc.
Individual Name: Eric Breeze
Location State: IL Country: US
View the Interpretation Document
Response text:
April 2, 2025
Eric Breeze
Manager of Project Management
Chemring Energetic Devices, Inc.
2525 Curtiss Street
Downers Grove, IL 60515
Reference No. 24-0095
Dear Mr. Breeze:
This letter is in response to your October 16, 2024, phone call and subsequent email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to explosives packaging requirements—specifically—packaging prescribed under an EX-approval. For an approved explosive, you ask whether adding desiccant bags and humidity indicator cards to the interior of the sealed plastic bag (i.e., the inner packaging) affects the classification of the explosive article and whether it needs to be explicitly stated in a packaging note.
The answer is no. A new explosive is an explosive produced by a person who has not previously produced that explosive or has made a change in the formulation, design, or process to alter any of the properties of the explosive—see 49 CFR § 173.56(a). It is the opinion of this office that including desiccant bags and/or humidity indicator cards in the packaging with the article are methods by which a manufacturer can ensure quality control of their products, and do not affect classification of the article provided that their placement does not interfere with any mitigating features of prescribed packaging. Therefore, adding them to a packaging utilized for transport under your approval does not necessitate modifying the existing packaging note to include them.
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
173.56(a)