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Interpretation Response #18-0049

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

Interpretation Response Details

Response Publish Date: 02-12-2019
Company Name: JM Ship, LLC    Individual Name: Michael Hopkins
Location state: VA    Country: US

View the Interpretation Document

Response text:

Dec 11, 2018

Michael Hopkins
JM Ship, LLC
650 Chautauqua Avenue
Portsmouth, VA  23707

Reference No. 18-0049

Dear Mr. Hopkins:

This letter is in response to your March 27, 2018, email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to stowage of Class 1 (explosive) material.  Specifically, you seek confirmation of your understanding that the stowage provision in § 176.116(e)(1) prohibits Class 1 (explosive) material from being stowed at any location vertically, either above or below, from machinery space, even if there is an intervening compartment.

Your understanding is correct.  Section 176.116(e)(1) states, “Class 1 (explosive) materials must be stowed as far away as practicable from any accommodation spaces or any machinery space and may not be stowed directly above or below such a space.”  Therefore, Class 1 (explosive) materials may not be stowed anywhere above or below any accommodation spaces or machinery space.

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


Regulation Sections

Section Subject
§ 176.116 General stowage conditions for Class 1 (explosive) materials