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Interpretation Response #14-0143

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

Interpretation Response Details

Response Publish Date: 04-22-2015
Company Name: Military Ocean Terminal Concord    Individual Name: Mr. David Arange
Location state: CA    Country: US

View the Interpretation Document

Response text:

April 22, 2015

David Arange
Ammunition Surveillance Inspector
Military Ocean Terminal Concord
Bldg. 542
410 Norman Ave
Concord, CA 94520

Ref. No.: 14-0143

Dear Mr. Arange:

This responds to your July 10, 2014 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the vessel stowage requirements for rockets with bursting charges. In your letter, you state that you offer for transportation "UN0181, Rockets, with bursting charge, 1.1E, II" by vessel. You note that "UN0181, Rockets, with bursting charge" are assigned the vessel stowage category "04" in the October 1, 2013 edition of the HMR. Further, you provide pictures and drawings entitled "Minimum Procedures Applicable to the Handling, Stowage, and Bracing Aboard Ships and Barges of the Rocket POD/Container (RP/C) for the Multiple Launch Rocket System (MLRS)." You ask whether these rockets must be stowed in a closed storage container for below deck stowage, or is the RP/C suitable as a storage container for below deck stowage?

Based on the pictures and drawings of the MLRS you provided in your letter, it is the opinion of this Office that the MLRS meets the definition of a closed cargo transport unit for Class 1 (explosive) materials. The definition of a "closed cargo transport unit for Class 1 (explosive) materials" means "a freight container or transport vehicle that fully encloses the contents by permanent structures and can be secured to the ship's structure and are, except for the carriage of division 1.4 explosives, structurally serviceable (see § 176.172)."

Based on the pictures you provided, the pods in question fully enclose the contents, are able to be secured to the ships structure due to their design, and are structurally serviceable. The definition of a "freight container" § 171.8 is " a reusable container having a volume of 64 cubic feet or more, designed and constructed to permit being lifted with its contents intact and intended primarily for containment of packages during transportation." The MLRS described in your request meets this definition of a freight container.

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

176.172, 171.8

Regulation Sections

Section Subject
§ 171.8 Definitions and abbreviations