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Interpretation Response #04-0258 ([Military Surface Deployment and Distribution Command])

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

Interpretation Response Details

Response Publish Date:

Company Name: Military Surface Deployment and Distribution Command

Individual Name:

Location State: VA Country: US

View the Interpretation Document

Response text:

Jan 18, 2005


Mr. Joseph P. Dugan                 Reference No. 04-0258
Safety & Occupational Health Specialist
Military Surface Deployment and Distribution Command
661 Sheppard Place
Fort Eustis, VA 23604-1644

Dear Mr. Dugan:

This responds to your letter requesting clarification of the requirements for segregation of explosives under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether transportation of Division 1 .4S detonators in a dromedary box on a motor vehicle that is also transporting a trailer loaded with Division 1.1, 1.2, and 1.3 materials satisfies the segregation requirements for motor carrier transportation.

The answer is no. Section 177.835(g) prohibits the transportation of detonators on the same motor vehicle with any Division 1.1, 1.2, or 1.3 material (except other detonators, detonator assemblies, or boosters with detonators), detonating cord Division 1.4 material, or Division 1.5 material unless the conditions specified in § 177.835(g)(l), (2), or (3) are met. A “motor vehicle” is defined as any number of transport vehicles powered by the same motor or engine (except vehicles that travel by rail or trolley). A “transport vehicle” is a cargo-carrying vehicle, such as an automobile, van, tractor, truck, or rail car used for the transportation of cargo by any mode. Each cargo-carrying body (such as a trailer or dromedary box) is a separate transport vehicle.

You suggest that the term “motor vehicle” as used in § 177.835(g) should be interpreted to mean “transport vehicle” to permit Division 1.4S detonators to be transported on the same motor vehicle with Division 1.1, 1.2, and 1.3 material. We do not agree. The clear intent of § 177.83 5(g) is to prohibit such transportation except under the conditions specified. You may petition for a regulatory change under the procedures established in 49 CFR 106.95 applicable to petitions for rulemaking.

I hope this satisfies your request.



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


Regulation Sections

Section Subject
177.835 Class 1 materials