Interpretation Response #22-0090
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
November 2, 2022
Mr. Joseph Murphy
16825 Northchase Drive
Houston, TX 77060
Reference No. 22-0090
Dear Mr. Murphy:
This letter is in response to your September 2, 2022, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to § 172.102, special provision 114 (SP 114). Specifically, you ask questions regarding the explosive weight of shaped charges for jet perforating guns (JPGs).
We have paraphrased and answered your questions as follows:
Q1. You ask whether the conditions outlined in SP 114(a) mean that only the explosive weight of the shape charges assembled in the JPGs count towards the 90.5 kg (200 pounds) limit per vehicle and not the other possible explosive components of a loaded JPG (e.g., a detonator cord or a booster).
A1. The answer is yes. The 90.5 kg (200 pounds) limit per vehicle applies to the explosive weight of the shaped charges of the JPGs and does not include other explosive articles in the JPG such as a detonator cord or a booster.
Q2. You ask whether the net explosive weight of other explosives shipped in accordance with § 177.848 on the same transport vehicle needs to be taken into consideration when transporting loaded JPGs that do not exceed the 90.5 kg (200 pounds) limit per vehicle.
A2. The answer is no. Other explosives offered for transportation on the transport vehicle are not counted towards the 90.5 kg (200 pounds) limit per vehicle.
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
|§ 177.848||Segregation of hazardous materials|