Interpretation Response #98-0185

Interpretation Response Details

August 5, 1999

Mr. Mark Baca                                   Ref. No. 98-0185
U.S. Department of Energy
P.O. Box 5400
Albuquerque, NM 87185-5400

Dear Mr. Baca:

This is in response to your letter concerning the packaging of explosives under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  We apologize for the delay in responding to your request and hope it has not caused you any inconvenience.

Based upon the scenarios you provided, your questions have been paraphrased and answered as follows:

Ql:        Does the definition of a packaging in § 171.8 mean that all of the inner packagings, including the innermost plastic bags or plastic bottles, tape, bubble pack, or other void filler, foam lining, inner drum coatings, metal drum, or other outside container must be compatible with, and impermeable to, the explosive?

Al:        Yes.  Section 173.60 (b) (9) states that packagings must be made of materials compatible with, and impermeable to, the explosives contained in the package, so that neither interaction between the explosives and the packaging materials, nor leakage, causes the explosive to become unsafe in transportation, or the hazard division or compatibility group to change (see § 173.24(e)(3) (ii).

Q2:      How far into a particular package must the concept of impermeability be carried?  If the innermost container (e.g., plastic bag or plastic bottle) and the outside packagings are impermeable to the explosive, do all packagings used still need to be compatible and impermeable to the explosive?

A2:       Yes.  The term "packaging" in § 173.60(b) (9) is not limited to inner or outer packagings only.  A packaging as defined in § 171.8 means a receptacle and any other components or materials necessary for the receptacle
to perform its containment function in conformance with the minimum packing requirements in the HMR.

Q3:      Do explosives that are sealed inside a 1.4 self-contained component with a housing that is compatible and impermeable to the explosive, still have to show that all packagings used are compatible and impermeable to the explosive?

A3:       It depends on the way the explosive substance is "sealed" within an explosive article.  If there is a chance of leakage, the answer is yes.

Q4:      Are metal packagings required to not generate or accumulate sufficient static electricity to cause a detonation of the substance or article?

A4:       No. This requirement is for plastic packagings only.

I hope this satisfies your request.

Sincerely,

Delmer F. Billings
Chief, Standards Development
Office of Hazardous Materials Standards

173.60

Regulation Sections