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Interpretation Response #04-0273 ([RUAG Ammorech GmbH] [Dr. Bernd E. Niekisch])

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

Interpretation Response Details

Response Publish Date:

Company Name: RUAG Ammorech GmbH

Individual Name: Dr. Bernd E. Niekisch

Country: DE

View the Interpretation Document

Response text:

Dec 23, 2004


Dr. Bernd E. Niekisch                 Reference No. 04-0273
RUAG Ammorech GmbH
Kronacher StraBe 63
90765 Fuerth / Germany

Dear Dr. Niekisch:

This responds to your November 29, 2004 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if USG-05, a United States variation found in the International Air Transport Association (IATA) Dangerous Goods Regulations, requires “cartridges, small arms” manufactured outside of the United States to have an approval even if they are excepted from the approval process by § 17356(h). You indicate that your materials are classed as “cartridges for weapons, inert projectile or cartridges, small arms, UNOO12, 1.4S” and “cartridges for weapons, blank or cartridges, small arms, blank, UNOO14, 1.4S.”

The IATA regulations do not have official standing under the HMR. The regulations recognized by the HMR and authorized in § 171.11 of the HMR as an alternative to compliance with the HMR are the International Civil Aviation Organization (ICAO) Technical Instructions for the Transport of Dangerous Goods. The IATA Dangerous Goods Regulations are very similar to the ICAO Technical ] For example, the United States variation that you reference, is located in the “List of State Variations” found in 2.9.2 of the IATA Dangerous Goods Regulations; it is also found under “US — United States” variations in Attachment 3, Chapter 1 of the ICAO Technical Instructions.

The 2005 / 2006 edition of the ICAO Technical Instructions and the 2005 edition of the JATA Dangerous Goods Regulations provide additional clarification regarding the approval of materials falling under § 173.56(h). The clarified regulations state that “cartridges, small arms” of the kind listed in § 173.56(h) do not require prior approval or an EX-number. This additional information does not constitute a change; it is a clarification of USG-05 intended to notify the international community that § 173.56(h) of the HMR applies to domestically or internationally manufactured “cartridges, small arms” that transit the United States.






I hope the information is helpful. Please contact us if you require additional assistance.



John A. Gale
Chief, Standards Development
Office of Hazmat materials Standards


Regulation Sections

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