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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #12-0084 ([DOD Explosive Safety Board] [Mr. Brent E. Knoblett])

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

Interpretation Response Details

Response Publish Date:

Company Name: DOD Explosive Safety Board

Individual Name: Mr. Brent E. Knoblett

Location State: VA Country: US

View the Interpretation Document

Response text:

July 10, 2012


Mr. Brent E. Knoblett
DOD Explosive Safety Board
4800 Mark Center Drive Suite 16E12
Alexandria, VA 22350

Ref. No. 12-0084

Dear Mr. Knoblett:

This responds to your letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to technical names. Specifically, you ask whether the removal of § 172.102(c)(1) Special provision 101 in 2006 results in noncompliance for certain Department of Defense (DOD) explosive shipments. You state that certain DOD explosive shipments approved under generic descriptions such as "Articles, explosive, n.o.s." were formerly assigned Special provision 101 in column 7 of the § 172.101 Hazardous Materials Table that required the name of the particular substance or article to be specified as the technical name for the substance or article (e.g., "Fuze, Grenade, M219A2") in association with the basic description. You assert the current provisions in §§ 171.8 and 172.203(k) of the HMR do not permit technical names to be indicated in such a manner as former Special provision 101 required.

In a notice of proposed rulemaking (NPRM) published in the Federal Register on August 31, 2006 (71 FR 51895), we proposed to remove § 172.102(c)(1) Special provision 101. In the NPRM, we stated that with the introduction of the letter ''G'' in Column (1), which requires the n.o.s. and generic proper shipping names to be supplemented with the technical name of the hazardous material, Special provision 101 became obsolete. Consequently, because we did not receive public comment, the amendment was adopted as proposed in a final rule published in the Federal Register on December 29, 2006 (71 FR 78596).

We intend to address this issue in a future rulemaking. In the interim, because DOD TB 700-2 is incorporated by reference in its entirety in § 171.7 of the HMR, you may continue to use it as the authority for assigning technical names to certain explosive descriptions in accordance with former Special provision 101 as prescribed in DOD TB 700-2.

I trust 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

172.102 SP 101, 172.101, 171.7

Regulation Sections

Section Subject
171.7 Reference material