Interpretation Response #11-0166
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
September 15, 2011
Ms. Marie Easley-Cook
Safety Analyst Associate
2211 Old Earhart Road
Ann Arbor, MI 48105
Ref. No.: 11-0166
Dear Ms. Easley-Cook:
This responds to your July 1, 2011 letter regarding the requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171"180) applicable to the transportation of explosives. Your reference letter of interpretation number 08-0192 in which the Pipeline and Hazardous Materials Safety Administration (PHMSA) stated that "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 § 177.848(g), provided they are authorized for such transportation in the compatibility table for Class 1 materials in § 177.848(f)." You present a scenario where UN 0440, Charges, Shaped, 1.4D are shipped with UN 0255, Detonators, Electric, 1.4B, in the same trailer. You ask if these two materials can be shipped together in transportation.
The materials you describe may only be transported on the same motor vehicle if the requirements of § 177.835(g)(1), (2), and (3) are met. The compatibility chart in § 177.848(f) generally does not allow 1.4D and 1.4B materials to be shipped on the same vehicle but references the reader to Note 4. Note 4 directs the reader to § 177.835(g) which prohibits the transportation of detonators on the same motor vehicle with any Division 1.1, 1.2, or 1.3 material (except other detonator assemblies, boosters with detonators or other detonators), explosives for blasting, or detonating cord Division 1.4 material.
I hope this satisfies your inquiry. Please contact us if we can be of further assistance.
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
177.848(f), 177.835(g)(1) and (3)
|§ 177.848||Segregation of hazardous materials|