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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #23-0097

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

Interpretation Response Details

Response Publish Date:

Company Name: Hunting Titan, Inc.

Individual Name: Joseph Murphy

Location State: TX Country: US

View the Interpretation Document

Response text:

May 10, 2024

Joseph Murphy
Compliance Manager
Hunting Titan
16825 Northchase Drive
Suite 600
Houston, TX  77060

Reference No. 23-0097

Dear Mr. Murphy:

This letter is in response to your October 31, 2023, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to shipping papers. Specifically, you request clarification on the requirement to indicate the type of packages on a shipping paper, in accordance with § 172.202(a)(7), as it relates to transporting jet perforating guns (JPGs), shipped under the proper shipping name "UN0494, Jet perforating guns, charged, 1.4D." You ask what the package type should be to describe "UN0494, Jet perforating guns, charged, 1.4D" on a shipping paper, in accordance with § 172.202(a)(7).

Unless a specific packaging method has been prescribed by the Pipeline and Hazardous Materials Safety Administration (PHMSA) on an EX approval or applicable Department of Transportation (DOT) special permit, JPGs are typically transported unpackaged under the provisions of § 173.62, Packaging Instruction US1. Because your JPGs are transported as unpackaged articles, there is no packaging type to indicate on your shipping paper, as would otherwise be required under § 172.202(a)(7). Therefore, it is the opinion of this Office that for unpackaged articles described in this scenario, it is permitted to provide an accurate descriptor of the articles in lieu of a packaging type for the requirements of § 172.202(a)(7)—examples include "jet perforating guns," "JPGs," or "explosive articles."

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

Sincerely,

Steven Andrews
Acting Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division

172.202(a)(7), 173.62

Regulation Sections

Section Subject
172.202 Description of hazardous material on shipping papers
173.62 Specific packaging requirements for explosives