Interpretation Response #18-0049
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Dec 11, 2018
JM Ship, LLC
650 Chautauqua Avenue
Portsmouth, VA 23707
Reference No. 18-0049
Dear Mr. Hopkins:
This letter is in response to your March 27, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to stowage of Class 1 (explosive) material. Specifically, you seek confirmation of your understanding that the stowage provision in § 176.116(e)(1) prohibits Class 1 (explosive) material from being stowed at any location vertically, either above or below, from machinery space, even if there is an intervening compartment.
Your understanding is correct. Section 176.116(e)(1) states, “Class 1 (explosive) materials must be stowed as far away as practicable from any accommodation spaces or any machinery space and may not be stowed directly above or below such a space.” Therefore, Class 1 (explosive) materials may not be stowed anywhere above or below any accommodation spaces or machinery space.
I hope this information is helpful. Please contact us if we can be of further assistance.
Dirk Der Kinderen
Chief, Standards Development
Standards and Rulemaking Division
|§ 176.116||General stowage conditions for Class 1 (explosive) materials|