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Interpretation Response #98-0524 ([Hunt Shipmate, Inc.] [Mr. Steven Charles])

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

Interpretation Response Details

Response Publish Date:

Company Name: Hunt Shipmate, Inc.

Individual Name: Mr. Steven Charles

Location State: CA Country: US

View the Interpretation Document

Response text:

FEB 24, 1998


Mr. Steven Charles
Hunt Shipmate, Inc.
2615 Voorhees Avenue
Suite 6
Redondo Beach, CA 90278

Dear Mr. Hunt:

This is in response to your letter, telefax, and telephone conversation with a member of my staff on behalf of your client who would like to transport a device, described as an "ignition cartridge," under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You state that the device does not meet the definition of an explosive substance. The device is used to preheat a cutting torch used for underwater rescue, and for military and law enforcement operations. You also stated that if the device ruptured and the iron strips uncoiled, the device would probably heat to ignition in air.

Based on the information you submitted and information available to us, it is our opinion that this device should be described as "Pyrophoric metals, n.o.s., 4.2, UN 1383, I", and is subject to the HMR for the following reasons:

  1. The device contains a pyrophoric form of iron.
  2. The Hazardous Materials Regulations and the International Civil Aviation Organization Technical Instructions for the Safe Transportation of Dangerous Goods by Air provide no exceptions for pyrophoric metals.
  3. Your letter provided little detail about how testing was conducted on the device. Therefore, we assume that the 0.003" metal foil was punctured and the device was allowed to stand under ambient conditions. Under these conditions, the rate of heating would be so slow that a temperature rise of about 10°F would be noted. However, if the device is ruptured and the iron strips are uncoiled, the device would probably heat to ignition in air.

Your client can submit an application for exemption from § 173 .124(b), if it can be demonstrated that the completed device does not meet the criteria for a Division 4.2, and will not meet this division under any reasonable conditions occurring during transportation.

I hope this information is helpful. if you need additional assistance, do not hesitate to contact us.



Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards

Regulation Sections

Section Subject
173.124 Class 4, Divisions 4.1, 4.2 and 4.3-Definitions