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Interpretation Response #05-0289 ([ShipMate, Inc.] [Mr. Steven Charles Hunt])

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

Interpretation Response Details

Response Publish Date:

Company Name: ShipMate, Inc.

Individual Name: Mr. Steven Charles Hunt

Location State: CA Country: US

View the Interpretation Document

Response text:

May 3, 2006


Mr. Steven Charles Hunt                        Reference No. 05-0289
ShipMate, Inc.
18436 Hawthorne Blvd, Suite 201
Torrance, CA 90504

Dear Mr. Hunt:

This responds to your November 15, 2005 letter requesting clarification on § 173.166 regarding air bags and seat-belt pretensioners installed in vehicle subassemblies under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether the exception in § 173.1 66(d)(1) for air bags and seat-belt pretensioners also applies to other passenger-safety devices, such as roll-over protection systems.

Roll-over protection systems contain a small amount of explosive material used to release a spring-loaded roll bar that will protect the occupants in a convertible vehicle. The explosive has previously been classed as a Division 1.4S explosive and assigned the approval number EX-1998030106.

The exception in § 173.166 does not apply to this type of device. You may wish to apply for a special permit from the Office of Special Permits and Approvals in accordance with procedures in § 107.105 of the HMR.

I hope this answers you inquiry.



John A Gale
Chief, Standards Development
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.166 Safety devices