Interpretation Response #08-0192 ([Titan Specialties, Ltd.] [Ms. Shelly Espinoza])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Titan Specialties, Ltd.
Individual Name: Ms. Shelly Espinoza
Location State: TX Country: US
View the Interpretation Document
Response text:
April 1, 2010
Ms. Shelly Espinoza
Titan Specialties, Ltd.
143 HCR 4361
Milford, Texas 76670
Ref. No. 08-0192
Dear Ms. Espinoza:
This responds to your e-mail request for clarification of the segregation requirements for explosives under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether a typographical error exists in the introductory text of § 177.835(g) with regard to the transportation of Division 1.4 explosive materials, other than Division 1.4 detonating cord, on the same transport vehicle as detonators (except other detonators, detonator assemblies or boosters with detonators). It is your understanding that because there is no comma between the words "detonating cord" and "Division 1.4 material" in both sentences of the introductory text where they appear, it inadvertently prohibits the transportation of Division 1.4 material, other than Division 1.4 detonating cord, on the same transport vehicle as detonators under the conditions specified in the remainder of the paragraph. I apologize for the delay in responding and any inconvenience it may have caused.
Your understanding is not correct. Section 177.835(g) establishes requirements for loading various types of explosive materials on the same transport vehicle. In accordance with this section, detonator assemblies or boosters may not be transported on the same motor vehicle as explosive material assigned to Division 1.1., 1.2, or 1.3; detonating cord that is assigned to Division 1.4; or explosive material assigned to Division 1.5. Division 1.4 materials (other than Division 1.4 detonating cord) may be transported on the same vehicle as detonator assemblies or boosters provided they are authorized for such transportation in the compatibility table for Class 1 materials in § 177.848(f).
Section 177.835(g) authorizes detonators to be transported on the same motor vehicle as explosive material assigned to Division 1.1., 1.2, or 1.3; detonating cord that is assigned to Division 1.4; or explosive material assigned to Division 1.5 under the conditions specified in paragraphs (g)(1) thru (g)(3). Division 1.4 materials (other than Division 1.4 detonating cord)
may be transported on the same motor vehicle as detonators without meeting the conditions specified in paragraphs (g)(1) thru (g)(3) of § 177.835(g) provided they are authorized for such transportation in the compatibility table for Class 1 materials in § 177.848(f).
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Hattie L. Mitchell
Chief, Regulatory Review and Reinvention
Office of Hazardous Materials Standards
177.835(g), 177.848(f)
Regulation Sections
| Section | Subject |
|---|---|
| 177.835 | Class 1 materials |
| 177.848 | Segregation of hazardous materials |