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Interpretation Response #08-0152 ([North American Services Group] [Mr. Bill Youngs])

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

Interpretation Response Details

Response Publish Date:

Company Name: North American Services Group

Individual Name: Mr. Bill Youngs

Location State: NY Country: US

View the Interpretation Document

Response text:

January 30, 2009

Mr. Bill Youngs

Director of Compliance

North American Services Group

1240 Saratoga Road

Ballston Spa, New York 12020

Ref. No. 08-0152

Dear Mr. Youngs:

This responds to your letter requesting clarification of shipping paper requirements for explosives under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether the quantity of a package containing "Cord, detonating, 1.4D, UN0289" is to be indicated on a shipping paper as the gross mass of the package or the net explosive mass of the detonating cord under the packaging exceptions for explosive articles in § 173.63(a).

The exception found in § 173.63(a) applies to "Cord, detonating, 1.1D, UN0065." Provided the conditions in § 173.63(a) are met, as applicable, such material may be offered and transported domestically as "Cord, detonating, 1.4D, UN0289." One applicable condition requires that the aggregate gross weight of all packages containing the reclassed detonating cord not exceed 45 kg (99 pounds) per conveyance specified. Although this value is not required to be indicated on a shipping paper, the package gross mass must be determined and not exceeded in order to utilize the exceptions for detonating cord under § 173.63(a).

As specified in § 172.202(a)(5)(i) for Class 1 materials, the quantity entered on a shipping paper for an explosive material that is also an article may be expressed in terms of the net mass of either the article or the explosive materials contained in the article. You state in your letter the net explosive mass of the article (detonating cord) is known and is marked on the exterior of the package by the manufacturer. You also state in your letter the net explosive mass of a partial roll of detonating cord can be determined by measuring its length.

Additionally, prior to using the exceptions for detonating cord in § 173.63(a), it must be determined that the detonating cord contains no more than 6.5 grams of explosive per 30 centimeter length. Thus, it is this calculated value that should be the quantity of material indicated on the shipping paper under § 172.202(a)(5)(i).

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

172.202(a)(5)(i), 173.63(a)

Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers
173.63 Packaging exceptions