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Interpretation Response #04-0086 ([Sporting Arms and Ammunition Manufacturers" Institute, Inc.] [Mr. Bob Van Duzer])

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

Interpretation Response Details

Response Publish Date:

Company Name: Sporting Arms and Ammunition Manufacturers" Institute, Inc.

Individual Name: Mr. Bob Van Duzer

Location State: PA Country: US

View the Interpretation Document

Response text:

Jun 8, 2004


Mr. Bob Van Duzer                 Reference No. 04-0086
Sporting Arms and Ammunition
Manufacturers’ Institute, Inc.
1339 Broad Run Road
Landenberg, PA 19350

Dear Mr. Van Duzer:

This is in response to your email concerning the requirement to indicate the “net explosive mass” when describing a Class 1 material on a shipping paper under § 172.202(a)(5)(i) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You describe a typical package for cartridges, small arms, as having a net mass of 10.66 kg, of which 0.333 kg is the mass of the smokeless powder contained in the cartridges. You ask whether the entry on the shipping paper should be the net mass of the explosive articles (i.e., the cartridges) or the explosive substance (e.g., smokeless powder) contained in the articles.

For an explosive that is an article, such as cartridges, small arms, it is our determination that the net mass of the article must be used to satisfy the total quantity requirement in
§ 172.202(a)(5)(i). As a practical matter, it is easier, and in certain instances necessary, for an offeror to determine and provide the net mass of the article. For example, the net mass of an article must be used to ensure compliance with the per package quantity limitations set forth in Column 9 of the § 172.101 Hazardous Materials Table. See
§ 172.101(j)(3).

For operational purposes, such as for stowage and segregation of large quantities of explosives or determining the quantity of explosives that can be transported on a vessel [ § 176.142(b)], it also may be necessary to obtain the net explosive mass (weight) of the explosive substances contained in articles from other data sources.

We have submitted a paper (copy enclosed) to clarify this shipping paper requirement in regard to a similar provision in the United Nations Model Regulations on the Transport of Dangerous Goods and also intend to clarify the HMR in the near future.
I trust this satisfies your inquiry. If we can be of further assistance, please contact us.



Edward T. Mazzullo
Director, Office of Hazardous Materials Standards


Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers