Interpretation Response #04-0113 ([General Dynamics - OTS] [Mr. John Wells])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: General Dynamics - OTS
Individual Name: Mr. John Wells
Location State: IL Country: US
View the Interpretation Document
Response text:
May 26, 2004
Mr. John Wells Reference No. 04-0113
Environmental Specialist
General Dynamics - OTS
Environmental and Regulatory Compliance
8820 Route 148 South
Marion, IL 62959
Dear Mr. Wells:
This is in response to your letter dated April 29, 2004 regarding the shipment of 30 millimeter primed ammunition cases for laboratory testing under the requirements of the Hazardous Materials Regulations (HMR: 49 CFR Parts 171-180). You state that each case has a 0.25 inch hole drilled in its sidewall and contains an empty flash tube and no propellent. Additionally, an inert projectile will be crimped into each case. You would like to know if the EX number assigned to the primed case would still be appropriate for your shipment and if Special Provision 50 would still apply.
It is our opinion that by drilling a hole in the side of a shell casing and crimping an inert projectile into the neck of the case you are not changing the classification of the explosive. Therefore, according to the information you provided, the EX number assigned to a primed case would still be accurate for your casings.
According to Special Provision 50 a material classed as “Cases, cartridge, empty with primer” that is constructed of metal or plastic and meets the classification criteria of Division 1.4 is not regulated for domestic transportation. From the information you provided, it is our opinion that your casings meet Special Provision 50 and, therefore, are not regulated for domestic transportation.
I hope this satisfies your request.
Sincerely,
Johan A. Gale
Chief, Standards Development
0ffice of Hazardous Materials Standards
173.56, 173.59