Interpretation Response #15-0023 ([Institute of Makers of Explosives] [Ms. Cynthia Hilton])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Institute of Makers of Explosives
Individual Name: Ms. Cynthia Hilton
Location State: DC Country: US
View the Interpretation Document
Response text:
March 24, 2015
Ms. Cynthia Hilton
Executive Vice President
Institute of Makers of Explosives
1120 Nineteenth St. NW Suite 310
Washington, DC 20036
Reference No. 15-0023
Dear Ms. Hilton:
This is in response to your January 29, 2015 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to packaging instruction US 1 in the Table of Packing Methods in § 173.62. You ask if the text "is not subject to damage by contact" is intended to prohibit any contact with other perforating guns or articles in the load, or is only intended to prohibit contact that under conditions normally incident to transportation that could cause damage.
Packaging instruction US 1 only prohibits contact with other perforating guns or articles in the load that could cause damage. Mere contact between perforating guns is not a violation of US 1 (1)(d)(i) unless the contact allows for movement between the contacting guns that could cause damage by contact. Therefore, perforating guns that are touching, but that are appropriately secured for conditions normally incident to transportation, would be compliant with the requirements of US 1 (1)(d)(i).
I trust this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
Duane Pfund
International Standards Coordinator
Standards and Rulemaking Division
173.62
Regulation Sections
| Section | Subject |
|---|---|
| 173.62 | Specific packaging requirements for explosives |