Did Your EX Approval Just Get X'd?

PHMSA announced last week that the agency has terminated a long list of explosives (EX) approvals held by dozens of US shippers. These EX approvals were terminated because shippers failed to provide evidence of compliance with a recent regulation change related to UN testing for specific 1.4S explosives.

In May of 2020, PHMSA published Final Rule HM-215O to harmonize the Hazardous Materials Regulations (HMR) with international requirements like the UN Model Regulations, ICAO Technical Instructions (TI), IATA Dangerous Goods Regulations (DGR), and others.

Rule HM-215O added to a requirement in Special Provision 347, impacting Division 1.4S hazardous materials shipped under these four UN numbers: 

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

These UN ID numbers now must pass UN 6(d) testing, the "Unconfined Package Test." Performance of this test verifies that any affects of accidental activation during transport will be confined to inside the package. 

PHMSA notified EX approval holders of the new requirement, and that their approvals would be terminated if they failed to provide evidence of successful 6(d) testing, about two years ago.  

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Tags: 49 CFR, explosives, hazmat shipping