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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 #17-0111

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: Susan JP Flanagan

Location State: DC Country: US

View the Interpretation Document

Response text:

Susan JP Flanagan
Legislative & Regulatory Counsel
Institute of Makers of Explosives
1212 New York Avenue NW Suite 650
Washington, DC 20005

Reference No. 17-0111

Dear Ms. Flanagan:

This letter is in response to your September 26, 2017, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to revisions made by the June 2, 2016, final rule titled "Hazardous Materials: Miscellaneous Amendments (RRR)" [HM‑218H; 81 FR 35483], which removed the packing group (PG) II designation for Class 1 explosives from the Hazardous Materials Table (HMT).

We have paraphrased and answered your questions as follows:

Q1. You describe a scenario in which a special permit issued prior to June 2, 2016, includes the packing group for Class 1 explosives, which has since been removed by the HM‑218H final rule. The special permit does not otherwise specify requirements related to the packing group. You ask whether the inclusion of the packing group in the hazardous materials description for the special permit requires the shipper to include the packing group on the shipping paper.

A1. The answer is no. Section 172.202(a)(4) provides a long-standing exception from the requirement to list a packing group on the shipping paper for Class 1 materials. The packing group was not required prior to the publication of the HM-218H final rule. The HM-218H final rule removed the packing groups to better clarify that packing groups on shipping papers are not required for certain HMT entries.

Q2. You ask whether shipping papers filled in accordance with Canadian Transportation of Dangerous Goods (TDG) Regulations are permitted to display a packing group.

A2. The answer is yes. As provided in § 171.12(a), a hazardous material classed, marked, labeled, placarded, described on a shipping paper, and packaged in accordance with the TDG Regulations, issued by the Government of Canada, may be offered for transportation and transported to or through the U.S., by motor vehicle or rail car. Therefore, such shipments may display a packing group in accordance with the TDG.

I hope this information is helpful. Please contact us if we can be of further assistance.


T. Glenn Foster
Chief, Regulatory Review and Reinvention
Standards and Rulemaking Division

Regulation Sections

Section Subject
171.12 North American Shipments
172.202 Description of hazardous material on shipping papers