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Interpretation Response #08-0119

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

Interpretation Response Details

Response Publish Date: 11-17-2008
Company Name: Bluegrass Army Depot    Individual Name: Ms. Gretchen Schmidt
Location state: KY    Country: US

View the Interpretation Document

Response text: November 17, 2008

Ms. Gretchen Schmidt
Bluegrass Army Depot
431 Battlefield Memorial Highway
Richmond, KY 40475-5070

Reference No. 08-0119

Dear Ms. Schmidt:

This is in response to your e-mail asking whether materials with the proper shipping name "Fuzes, detonating," fall under the category of "detonators" and are subject to the requirements prescribed in § 177.835(g) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). We apologize for the delay in responding and any inconvenience this may have caused.

The answer is yes. The HMR defines a "detonator" in § 173.159 as an article that is designed to start a detonation train of an explosive material, and a "fuze" as an article designed to start a detonation or deflagration in ammunition that incorporates mechanical, electrical, chemical, or hydrostatic components and generally protective features. The HMR list all detonating fuzes by identification number under § 173.61(c), including UN 0106, UN 0107, UN 0257, and UN 0367 for "Fuzes, detonating," and UN 0408, UN 0409, and UN 0410 for "Fuzes, detonating with protective features." The list also includes UN numbers for detonators that are listed in the United Nations Recommendations on the Transport of Dangerous Goods, the International Civil Aviation Organizations (ICAO"s) Technical Instructions for the Safe Transport of Dangerous Goods by Air (Technical Instructions), and the International Maritime Dangerous Goods (IMDG) Code.

Section 173.61 prescribes requirements for packaging explosives with other materials. Paragraph (c) of this section prohibits detonators from being packed with other Class 1 materials except other detonators that meet the compatibility requirements prescribed in § 173.61(e). In addition, § 177.835(g) prohibits detonators from being transported on the

same motor vehicle with any Division 1.1, 1.2, or 1.3 explosive material (except other detonators, detonator assemblies, or boosters with detonators), Division 1.4 detonating cord, or Division 1.5 material unless the detonating materials are placed in protective packagings prescribed in § 177.835(g)(1), (g)(2), or (g)(3).

I hope this satisfies your request.


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

177.835(g), 173.159

Regulation Sections

Section Subject
§ 177.835 Class 1 materials