Interpretation Response #01-0092 ([Alliant Aerospace Company] [Mr. John D. Morgan])

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

Interpretation Response Details

Response Publish Date: 06/28/2001

Company Name: Alliant Aerospace Company

Individual Name: Mr. John D. Morgan

Location State: UT Country: US

View the Interpretation Document

Response text:

JUN 28, 2001

Mr. John D. Morgan                     Reference No.: 01-0092

Traffic Coordinator
Alliant Aerospace Company

P. O. Box 98
Magna, UT 84044-0098

Dear Mr. Morgan:

This is in response to your April 12 letter requesting clarification of the marking and labeling requirements for shipments of large and robust rocket motors, Division 1.1 C or I.3C, under Packing Instruction 130 of § 173.62(c) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You stated that these articles are transported unpackaged, affixed to cradles secured on a flatbed or packaged in handling devices loaded in van trailers.

The marking and labeling requirements for these large and robust rockets depend on whether they are construed to be bulk or non-bulk packagings. Section 173.62(a) states that only non­bulk packagings are authorized under paragraph (c). Accordingly, § 172.301 states that a non­bulk packaging containing a hazardous material shall be marked with the proper shipping name and the identification number. Additionally, § 172.320 prescribes that a package containing Class 1 materials shall be marked with the EX-number. Under § 172.400, the packages would be labeled unless otherwise excepted; for example, by § 172.400(a)(5) or § 172.400a(a)(2). The markings and labels must be placed directly on the article, i.e. the rocket motor, on a tag or affixed by other suitable means.

I trust this information is helpful.

Sincerely,

Hattie L. Mitchell
Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

173.62

Regulation Sections