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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #06-0173 ([Schlumberger, Ltd.] [Mr. Paul Lezak])

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

Interpretation Response Details

Response Publish Date:

Company Name: Schlumberger, Ltd.

Individual Name: Mr. Paul Lezak

Location State: TX Country: US

View the Interpretation Document

Response text:

Sep 18, 2006

Mr. Paul Lezak                 Reference No. 06-0173
Schlumberger, Ltd.
14910 Airline Road
Rosharon, TX 77583

Dear Mr. Lezak:

This is in response to your August 3, 2006, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether overpacks containing explosive materials need to be marked with appropriate EX-numbers.

The HMR do not require the marking of EX-numbers on overpacks. Section 173.25 requires each overpack to be marked with the proper shipping names and identification numbers required under the HMR for each hazardous material contained within the overpack, unless those markings are visible. The other marking requirements in § 173.25 are conditional marking requirements that are unrelated to EX-number markings and are irrelevant to this scenario. Therefore, dual marking of the EX-numbers on both the packages and overpacks is not required. However, to avoid the possible frustration of your shipment you may include on the shipping paper, in association with the shipping description, the EX-number, product code or national stock number of each explosive item described under a proper shipping description.

I hope this satisfies your request.



Charles E. Betts
Senior Transportation Specialist
Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.25 Authorized packagings and overpacks