Interpretation Response #16-0202
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
September 29, 2017
Timothy W. Kenney
Valley View Industries, Inc.
8785 E 2500 North Road
Cornell, IL 61319
Reference No. 16-0202
Dear Mr. Kenney:
This letter is in response to your December 15, 2016, email and our subsequent phone conversation with your colleague requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to the transportation of Class 1 material on a multipurpose bulk truck (MBT). Specifically, you indicate that you transport “UN0332, Explosive blasting, type E, 1.5D” and ask if the HMR allows for the transportation of “UN0042, Boosters, without detonator, 1.1D,” “UN0030, Detonators, electric, for blasting, 1.1B,” and “UN0361, Detonator assemblies, non-electric, for blasting, 1.4B” on the same MBT.
The answer is yes. Class 1 material, as authorized in § 172.101, may be transported in a MBT when packaged in accordance with § 173.66. Section 177.835(d) excepts MBTs from segregation requirements of § 177.848 when transported in accordance with § 173.66. Section 177.835(d) also requires that MBTs transporting Class 1 material with a Division 5.1, Class 8, or “NA1993, Combustible liquid, n.o.s., PG III” comply with segregation requirements of § 177.835(g). Since you are not transporting a Division 5.1, Class 8, or “NA1993, Combustible liquid, n.o.s.” with authorized Class 1 material, you are not subject to the requirements on § 177.835(g). Therefore, as long as all other requirements of the HMR and IME Standard 23 are met, “UN0332, Explosive blasting, type E, 1.5D,” “UN0042, Boosters, without detonator, 1.1D,” “UN0030, Detonators, electric, for blasting, 1.1B,” and “UN0361, Detonator assemblies, non-electric, for blasting, 1.4B” may be transported on the same MBT.
I hope this information is helpful. Please contact us if we can be of further assistance.
Dirk Der Kinderen
Chief, Standards Development
Standards and Rulemaking Division
172.101, 173.66, 177.835(d), 177.848, 177.835(d), 177.835(g)
|§ 177.848||Segregation of hazardous materials|