Interpretation Response #12-0052 ([Doughty & Carson, PLLC] [Mr. Oliver D. Adams Hodges])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Doughty & Carson, PLLC
Individual Name: Mr. Oliver D. Adams Hodges
Location State: TN Country: US
View the Interpretation Document
Response text:
March 23, 2012
Mr. Oliver D. Adams
Hodges, Doughty & Carson, PLLC
P.O. Box 869
617 W. Main Street
Knoxville, Tennessee
Ref. No.: 12-0052
Dear Mr. Adams:
This responds to your February 8, 2012 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the packaging exceptions for cartridges, small arms. Specifically, you ask if the only option § 173.63(b)(2) permits is for small arms ammunition/cartridges to be fit snugly into an inner box and then placed securely into an outside box. Additionally, you provide a spreadsheet with a list of numerous packaging scenarios for small arms ammunition and ask whether they comply with § 173.63(b)(2).
As specified in § 173.63(b)(2), there are multiple packaging options for the cartridges, small arms and cartridges, power devices as a limited quantity or other regulated material (ORM-D). As specified in paragraph (b)(2)(i), ammunition must be packed: (1) in inside boxes, (2) in partitions which fit snugly in the outside packaging, or (3) in metal clips. Depending on which of the three options was chosen, the inside boxes, the partitions, or the metal clips must be further packed in securely-closed strong outside packagings, as specified in paragraph (b)(2)(iii). Therefore, provided that you comply with all other relevant provisions in § 173.63(b)(2), your packaging would be acceptable for the transportation of a limited quantity of cartridges, small arms, and cartridges, power devices. In addition, provided your numerous packaging scenarios for small arms ammunition utilize a permitted packaging configuration, they also would be acceptable to transport limited quantities of the above hazardous materials per the HMR.
I hope this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
173.63
Regulation Sections
| Section | Subject |
|---|---|
| 173.63 | Packaging exceptions |