Interpretation Response #18-0153
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: FabTech Services, LP
Individual Name: Jason Streber
Location State: TX Country: US
View the Interpretation Document
Response text:
May 7, 2020
Jason Streber
FabTech Services, LP
2008 Industrial Boulevard
Rockwall, TX 75087
Reference No. 18-0153
Dear Mr. Streber:
This letter is in response to your November 14, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of jet perforating guns. Specifically, you seek clarification on the packaging requirements of packing method US 1 from the Table of Packing Methods in § 173.62 for jet perforating guns.
We have paraphrased and answered your questions as follows:
Q1. You ask whether US1 (1)(c) permits the use of end caps that incorporate a metal disk to provide complete metal-to-metal contact, but which are secured with plastic fittings.
A1. The answer is yes. Packing method US 1 (1)(c) requires that, "each shaped charge if not completely enclosed in glass or metal, must be fully protected by a metal cover after installation in the gun." The cover you describe would give complete metal coverage around the shaped charges and therefore meets the requirements, provided that the plastic fittings are sufficiently robust to prevent movement of the cover during normal transport conditions.
Q2. You provide images of an all-metal cover design and ask whether it meets the requirements of US 1 (1)(c).
A2. The answer is yes. Packing method US 1 (1)(c) requires that, "each shaped charge if not completely enclosed in the glass or metal, must be fully protected by a metal cover after installation in the gun." Based on the images provided, it is the opinion of this Office that the all-metal cover design meets the requirements of US 1 (1)(c).
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division
173.62
Regulation Sections
| Section | Subject |
|---|---|
| 173.62 | Specific packaging requirements for explosives |