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Interpretation Response #09-0022 ([NASA Wallops Flight Facility] [Mr. Ernest Cornwell])

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

Interpretation Response Details

Response Publish Date:

Company Name: NASA Wallops Flight Facility

Individual Name: Mr. Ernest Cornwell

Location State: VA Country: US

View the Interpretation Document

Response text:

April 10, 2009





Mr. Ernest Cornwell

NASA Wallops Flight Facility

32400 Fulton Street, Building M-16 Room 107

Wallops Island, VA 23337

Ref. No.: 09-0022

Dear Mr. Cornwell:

This is in response to your letter dated January 23, 2009 requesting clarification of the Hazardous Material Regulations (HMR; 49 CFR Parts 171-180) applicable to the classification of explosives. In your letter you describe a parachute recovery system that uses reefing line cutters classed and approved by the Department of Transportation (DOT) as "Cutters, cable, explosive, 1.4S, UN0070." You ask if a reefing line cutter packed in the parachute recovery system may also be described as "Cutters, cable, explosive, UN0070, 1.4S."

The answer is no. A parachute recovery system with a previously approved reefing line cutter installed would be considered a new explosive under § 173.56 and must be classed by DOT. In accordance with § 173.56, a person requesting approval of a new explosive must submit to the Associate Administrator a report of the examination and assignment of a recommended shipping description, division, and compatibility group. If the Associate Administrator finds the approval request meets the regulatory criteria, the new explosive will be approved in writing and assigned an EX number. The Office of Hazardous Materials Approvals may be reached by telephone at (202) 366-4511.

I trust this satisfies your inquiry. If we can be of further assistance, please contact us.


Charles E. Betts

Chief, Standards Development

Office of Hazardous Materials Standards


Regulation Sections

Section Subject
173.56 New explosives-definition and procedures for classification and approval