Interpretation Response #20-0036
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
June 4, 2020
Steven Charles Hunt
780 Buckaroo Trail, Suite D
Sisters, OR 97759
Reference No. 20-0036
Dear Mr. Hunt:
This letter is in response to your April 20, 2020, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transport of Class 1 (explosive) materials. Specifically, you ask whether your material, "UN0475, Substances, explosive, n.o.s., 1.1D" may be shipped by vessel in a refrigerated freight container.
In your email, you state that although Part 176 (Carriage by Vessel) authorizes the use of closed freight containers, there is no specific reference made to refrigerated freight containers. In addition to your email, you provided supplementary material on the refrigerated freight container that you intend to use to transport your explosive material. This included information on the specifications for a safe type refrigerated container which would be in compliance with 49 CFR 176.76(a)(9). You ask whether §§ 176.116(a) or 176.118(b) would prevent the use of refrigerated freight containers when shipping the explosive material "UN0475, Substances, explosive, n.o.s., 1.1D."
Based on the information you provided in your email, your explosive material may be shipped in the referenced refrigerated freight container. As specified in § 176.116(a), Class 1 (explosive) materials must be stowed as far away as practicable from any potential source of heat or ignition. This includes potential sources of heat or ignition in refrigerated or heated cargo transport units unless they are of a type designed to operate in a hazardous environment. Since the refrigerated freight container you describe is a type designed to operate in a hazardous environment, it may be used to transport Class 1 (explosive) materials by vessel.
I hope this information is helpful. Please contact us if we can be of further assistance.
T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division
176, 176.76(a)(9), 176.116(a), 176.118(b)
|§ 176.118||Electrical requirement|