DEKRA Process Safety Alert: New Explosive Approvals Requirements for Select 1.4S Articles

Recently Adopted Rule Affects Thousands of Explosive Approvals

DEKRA Process Safety Alert: New Explosive Approvals Requirements for Select 1.4S Articles

Issued on May 11, 2020, the HM-215O Final Rule impacts more than 2,200 explosive approvals. HM-2150 is a major realignment of DOT Hazardous Materials Regulation to assure ongoing compatibility with international efforts for global harmonization.

This recently adopted rule includes a re-evaluation of certain explosives that were previously classified as 1.4S. Explosives classified as 1.4S are allowed to be shipped as cargo on passenger aircraft, which may be the only way to quickly reach remote destinations. In addition, ocean shipments of 1.4S explosives provide substantial flexibility when compared to other explosive classifications.

You must comply with the new requirements by May 10, 2021 if you ship or supply explosive items classified under the following UN numbers:

  • UN 0349 Articles, explosives, n.o.s.
  • UN 0367 Fuzes, detonating
  • UN 0384 Components, explosive train, n.o.s.
  • UN 0481 Substances, explosive, n.o.s.

Implementing the New Requirements

The Pipeline and Hazardous Materials Safety Administration (PHMSA) added special provision 347 to the 1.4S explosive entries listed above. This provision now requires each product to pass the UN 6(d) test (unconfined package test) to maintain classification.

If your existing approval already documents that the UN 6(d) criteria has been met, no action is required. Otherwise, you should communicate test results to PHMSA no later than April 10, 2021.

Know Your Options

To comply with these new requirements, you have three options:

1. Retain the 1.4S designation: Test the product at a DOT approved lab and submit the report to PHMSA for approval. The deadline for submitting test results is April 10, 2021.

2. Reclassify to a division other than 1.4S: Submit a letter to PHMSA with appropriate information to reclassify the explosive as Division 1.4 other than compatibility group S. Be sure to supply justification for your compatibility group choice.

3. Request to terminate the Approval: Existing approvals that have not been re-evaluated will be terminated if the PHMSA does not receive information by May 10, 2021.

As a testing lab approved by the Associate Administrator of DOT to examine and make recommendations concerning explosives, DEKRA offers a comprehensive set of UN/DOT Energetics & Explosives Testing Services, as well as consulting to support hazardous material and explosives classification. To learn more, please call (609) 799-4449 extension 351 or contact us today!