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Interpretation Response #21-0028

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: McCallum Rock Drilling

Individual Name: Darren Amman

Location State: WA Country: US

View the Interpretation Document

Response text:

May 7, 2021

Darren Amman
McCallum Rock Drilling
123 Habein Road
Chehalis, WA  98532

Reference No. 21-0028

Dear Mr. Amman:

This letter is in response to your March 12, 2021, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to a cargo tank nameplate. You explain that McCallum Rock Drilling has three non-DOT specification cargo tanks that are used to transport "UN3375, Ammonium nitrate emulsion or Ammonium nitrate suspension or Ammonium nitrate gel, intermediate for blasting explosives, 5.1, PG II." You further explain that operations at the company were halted due to not having the correct nameplate on the cargo tanks. Additionally, you provided a photograph of the new nameplate that would be attached to the cargo tanks and you ask whether the information on the new nameplate meets the requirements of the HMR and the Institute of Makers of Explosives Safety Library Publication No. 23 (IME SLP-23), which is incorporated by reference in § 171.7 and authorized for use in § 173.66.

In accordance with IME SLP-23 Section I, (F)(3)(a), the manufacturer of non-DOT specification cargo tanks shall certify that each packaging is designed, constructed, and tested in accordance with the applicable standards of IME SLP-23. Also, in accordance with IME SLP-23 Section I, (F)(3)(d), a non-DOT specification cargo tank must include specific information on the nameplate. Based on the photograph you provided, the nameplate appears to be missing the following information:

  • Indication of whether the cargo tank is designed for either liquid or solid
  • Name and address of manufacturer
  • Maximum allowable working pressure
  • Maximum design pressure
  • Maximum lading temperature
  • Maximum weight of lading in pounds

If McCallum Rock Drilling addresses the missing information and all other applicable HMR and IME SLP-23 requirements are met, the new nameplate would be in compliance.

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


Dirk Der Kinderen
Chief, Standards Development Branch
Standards and Rulemaking Division

171.7, 173.66

Regulation Sections

Section Subject
171.1 Applicability of Hazardous Materials Regulations (HMR) to persons and functions
173.66 Requirements for bulk packagings of certain explosives and oxidizers