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Interpretation Response #04-0121 ([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:

Jun 17, 2004

 

Mr. John Wells                 Reference No. 04-0121
Environmental Specialist
General Dynamics - OTS
8820 Route 148 South
Marion, IL 62959

Dear Mr. Wells:

This responds to your May 5, 2004 letter requesting clarification on § 173.56 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) regarding new explosive approvals. Specifically, you ask whether a new explosives approval is required for any of the following revisions/changes to a current explosives approval: (1) part number of an explosive device changes; (2) revisions levels to a drawing; and (3) suffix numbers are added to a part number.

Your questions are paraphrased and answered as follows:

Q1. Part number of an explosive device changes.  If our engineering department changes the part number of our currently approved device, would this require a new DOT approval? There are no changes to the design, components, or energetic materials of this device.

Al. A new approval is not required. However, you must submit a request to the Office of Exemptions and Approvals in writing to include the new part number in your current approval.

Q2. Revision levels to a drawing.  If a part number for a drawing was changed to JW9000 Revision A, would this require a new approval? The revision may be as simple as a change in ink color used to mark the item. In addition, there are no changes to the design, components, or energetic materials of this device.

A2. You must request in writing that the Office of Exemptions and Approvals review this change to make a determination as to whether the revision is significant enough to warrant a new testing and approval review process or is a minor editorial revision request.

Q3. Suffix numbers added to a part numb.  (Due to design change, with no energetic material change). If a minor change to a device, such as number of threads or angle of chamber, and the new part number is now changed, would a new approval be required? There are no changes to the energetic materials or the functionality of this device.

A3. See answer A2 above.

I hope this answers your inquiry.
Sincerely,

 

John Gate
Chief, Standards Development
Office of Hazardous Materials Standards

173.56

Regulation Sections

Section Subject
173.56 New explosives-definition and procedures for classification and approval