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Interpretation Response #14-0237 ([Textron Systems, Weapons & Sensor Systems] [Mr. James Baustert])

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

Interpretation Response Details

Response Publish Date:

Company Name: Textron Systems, Weapons & Sensor Systems

Individual Name: Mr. James Baustert

Location State: MA Country: US

View the Interpretation Document

Response text:

July 16, 2015

Mr. James P. Baustert Jr.
Textron Systems, Weapon & Sensor Systems
201 Lowell St (EHS)
Wilmington, MA 01887

Ref. No. 14-0237

Dear Mr. Baustert:

This responds to your December 4, 2014 email request for clarification and your follow up email on January 8, 2015, on an explosives approval under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if revisions/changes to a product designation/part number requires a new explosives Classification of Explosives (COE) approval letter under § 173.56.

In your letter, you state that you occasionally need to modify and make minor changes to the device which does not change the function or safety of the item, (e.g., changing a part number and adding a "W" to the documentation to indicate changes to military Cluster Bomb Units). This revised part number will only be applied to two test munitions to designate them as specific test munitions for water targets. You ask if you may use your existing COE approval letter to cover this part number change.

The answer is no. You may not use your existing COE approval letter to add the revised part number. You must apply for a new updated COE approval letter that includes the information on the newly revised/changed part number in accordance with § 107.709. After review and approval, PHMSA will issue you a revised/updated COE approval letter that includes the original part number and the revised/change to the part number. To help facilitate faster processing, you may apply online for the revised COE approval letter at or email an application to If your changes will not affect the formulation, design, or process in a way that would alter the properties of the explosive, you may include a certification statement to that effect in your application.

I hope this answers your inquiry. If you need additional assistance, please contact this Office at (202) 366-8553.



Dirk Der Kinderen
Acting Chief, Standards Development Branch
Standards and Rulemaking Division

173.56, 107.709

Regulation Sections

Section Subject
107.709 Processing of an application for approval, including an application for renewal or modification
173.56 New explosives-definition and procedures for classification and approval