Interpretation Response #19-0091
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Baker Hughes
Individual Name: Jesse Rodriguez
Location State: TX Country: US
View the Interpretation Document
Response text:
December 2, 2019
Jesse Rodriguez
Baker Hughes
P.O. Box 546
Bay City, TX 77404
Reference No. 19-0091
Dear Mr. Rodriguez:
This letter is in response to your July 9, 2019, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to labeling requirements for jet perforating guns (JPGs). Specifically, you ask for clarification of labeling requirements when JPGs are palletized and banded together for transportation, and when several JPGs are assembled into a "staged gun-string" prior to use.
We have paraphrased and answered your questions as follows:
Q1. You ask whether the individual gun body of a JPG requires a label when palletized and banded together for transport.
A1. The answer is yes. JPGs, whether classified as a 1.1D or 1.4D explosive, are transported under packaging instruction US 1, found in the Table of Packing Methods in § 173.62. US 1 requires that the motor vehicle transporting the JPG must have a specially built rack or carrying case. This rack or carrying case is the packaging for the JPG. Each rack or carrying case must be labeled in accordance with Part 172, subpart D with the appropriate Division 1.1 or 1.4 label.
Q2. You ask whether the placement of a single hazard class label on a "staged gun-string" meets the labeling requirements of the HMR.
A2. The answer is yes. The "staged gun-string" would be treated as a single package, and duplicate labeling of each gun body making up the string would not be required in this scenario. It would, however, be permissible for each individual gun body in the string to bear the appropriate Division 1.1 or 1.4 label.
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 |