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Interpretation Response #02-0044 ([Zambelli Internationale Fireworks Mfg. Co. Inc.] [Ron Snyder])

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

Interpretation Response Details

Response Publish Date:

Company Name: Zambelli Internationale Fireworks Mfg. Co. Inc.

Individual Name: Ron Snyder

Location State: PA Country: US

View the Interpretation Document

Response text:

Jul 24, 2002

Mr. Ron Snyder                 Reference No. 02-0044
Zambelli Internationale
Fireworks Mfg. Co. Inc.
Safety Office
RD #1 Box 270 A
Edinburg, PA 16116

Dear Mr. Snyder:

This responds to your letter regarding the requirements in § 177.834(g) to secure hazardous materials packages against movement when transported by motor vehicle under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  You ask whether packages of Fireworks,.  Division 1.3G, that are overpacked would satisfy the prevention of motion requirements under 177.834(g). In addition, you ask whether the overpack is required to be secured within the motor vehicle.

The requirements in § 177.834(a) and (g) are met when the packages of hazardous materials are secured in a manner that precludes their movement within the transport vehicle, and between the packages themselves, under conditions normally incident to transportation.  These conditions most often include vehicle starting, stopping, cornering, accident avoidance, and varied road conditions.  If the packages are overpacked, the overpack itself must also be secured within the transport vehicle.

Specific methods for securing packages in a motor vehicle are not defined in the HMR.  However, general requirements which address protection of shifting cargo are found in the Federal Motor Carrier Safety Regulations (49 CFR Parts 300-399), specifically under §§ 393.100 to 393.106. These requirements allow varied methods of securement, such as blocking with other freight, banding or use of tie-downs or load-locks.

I trust this satisfies your inquiry.  Please contact us if we can be of further assistance.


Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
177.834 General requirements