Interpretation Response #03-0126 ([HQ US Army Joint Munitions Command 1] [Mr. Kelly W. Crooks])

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

Interpretation Response Details

Response Publish Date: 06/06/2003

Company Name: HQ US Army Joint Munitions Command 1

Individual Name: Mr. Kelly W. Crooks

Location State: IL Country: US

View the Interpretation Document

Response text:

Jun 6, 2003

Mr. Kelly W. Crooks                Reference No. 03-0126
Acting Chief, Safety/Rad Waste Office
HQ US Army Joint Munitions Command 1
Rock Island Arsenal
Rock Island, IL 61299-6000

This is in response to your May 7, 2003 letter requesting clarification of the requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 172-180) regarding the loading, transport and incidental storage of a lAG (explosive) material, other than fireworks, with other Class 1
(explosive) material, other than detonators, in compatibility groups C, D, E, or S by rail, vessel and highway . Your questions are paraphrased and answered below:

Q 1. Can a lAG (explosive) material be transported by rail with other Class 1(explosive)
material in compatibility groups C, D, E, or S?

AI. The answer is yes, with the following limitations:
• When the § 172.101 table or § 1720402 requires a package to bear a subsidiary hazard label, segregation appropriate to the subsidiary hazard must be applied when that segregation is more restrictive than that required by the primary hazard. However, hazardous materials of the same class may be loaded and transported together without regard to segregation required by any secondary hazard if the materials are not capable of reacting dangerously with each other and causing combustion or dangerous evolution of heat, evolution of flammable, poisonous, or asphyxiant gases, or formation of corrosive or unstable materials. (§ 174.81 (e )(6)).
• Explosive articles in compatibility group G, other than fireworks and those requiring special stowage, may be loaded and transported with articles of compatibility groups C, D, E, provided no explosive substances are carried in the same rail car. (§ 174 .. 81(g)(3)(vi)).

Q2. Can a 1.4G (explosive) material be transported by vessel with other Class 1 (explosive)
material in compatibility groups C, D, E, or S?

A2. The answer is yes, with the following limitations:
• Explosive articles in compatibility group G, other than fireworks and those requiring special stowage, may be stowed with articles of compatibility groups C, D, and E, provided no explosive substances are carried in the same compartment, portable magazine or transport unit. (Table 176.144(a), Note 1)

Q3. Can a l.4G (explosive) material be transported by public highway with other Class 1
( explosive) material in compatibility groups C, D, E, or S?

A3. The answer is yes, with the following limitations:
• When the § 172.101 table or § 172.402 of this subchapter requires a package to bear a subsidiary hazard label, segregation appropriate to the subsidiary hazard must be applied when that segregation is more restrictive than that required by the primary hazard. However, hazardous materials of the same class may be loaded and transported together without regard to segregation required by any secondary hazard if the materials are not capable of reacting dangerously with each other and causing combustion or dangerous evolution of heat, evolution of flammable, poisonous, or asphyxiant gases, or formation of corrosive or unstable materials. (§ 177.848( e)( 6))
• Explosive articles in compatibility group G, other than fireworks and those requiring special handling, may be loaded, transported and stored with other explosive articles of compatibility groups C, D, and E, provided that explosive substances (such as those not contained in articles) are not carried in the same vehicle. (§ 177.848(g)(3)(vi))
• See § 177.835(g) pertaining to detonators. (§ 177.848(g)(iv))

Q4. Is it the shipper's responsibility to determine whether a risk of "dangerous reaction"
between materials exist, and is the shipper required to document that decision in writing?

A4. The answer is yes. Section 173.24( e)( 4) states ... "hazardous materials may not be packed
or mixed together in the same outer packaging with other hazardous or non-hazardous materials if such materials are capable of reacting dangerously with each other and causing: combustion or dangerous evolution of heat; evolution of flammable, poisonous, or asphyxiant gases; or formation of unstable or corrosive materials." Also see § 173.21(e). It is the shipper's responsibility to determine whether any of these dangerous reactions can occur. Such determinations are not required to be verified by or submitted to this Office.
I hope this satisfies your request.

Sincerely,

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

Regulation Sections