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Interpretation Response #03-0157

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

Interpretation Response Details

Response Publish Date: 07-31-2003
Individual Name: Mr. Clark B. Huggins
Location state: UT    Country: US

View the Interpretation Document

Response text:

Jul 31, 2003


Mr. Clark B. Huggins               Reference No. 03-0157
P.O. Box 57
Bear River City, UT 84301

Dear Mr. Huggins:

This is in response to your June 24, 2003 letter requesting clarification of the requirements in the Hazardous Materials Regulations (HMR; 49 CFR Parts 172-180) regarding the general packaging requirements for explosives.  Your questions are paraphrased and answered below.

Q1.  Can wetted explosives be shipped during warm weather without the use of anti-freeze?

Al.  Section 173.60(b)(4) specifically states "[when] the packaging includes water that could freeze during transportation, a sufficient amount of anti-freeze, such as denatured ethyl alcohol, must be added to the water to prevent freezing." [Emphasis added] It is not possible for this Office to determine that in every situation where wetted explosives are shipped during warm weather, the wetted explosive would not encounter, during its transportation, freezing temperatures.  Therefore, it is the shipper"s responsibility based on the mode of transportation, as well as other transportation factors, whether their wetted explosives are liable to encounter conditions that could cause freezing to occur.

Q2.  When required, is only the amount of anti-freeze necessary to prevent freezing at the anticipated temperatures required?

A2.  Section 173.60(b)(4) states in part. . ."a sufficient amount of anti-freeze must be added to the water to prevent freezing .... When a percentage of water in the substance is specified, the combined weight of water and anti-freeze may be substituted." Therefore, the answer is yes.

Q3.  Can the use of anti-freeze be excluded, if some acceptable means of   temperature control is provided in the cargo space?

A3. The answer is no, the regulations specifically require that anti-freeze be used.  Other alternate controls may be authorized only under the terms of a DOT exemption (see § 107.105).

I hope this satisfies your request.



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


Regulation Sections

Section Subject
§ 173.60 General packaging requirements for explosives