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Assignment of EX Number:
Zukovich, Morhard & Wade, LLC has provided technical guidance for classifying more than twenty-five (25) new explosives substances and articles. Proper transportation hazard classification for an explosive, of course, culminates with the assignment of an EX Number. Much more specific than a Hazard Classification, an EX Number applies to a particular explosive formula and its packaging. The EX number is required for MSHA, DOT, ATF and State and Local authorities.
Regulatory Requirement for Testing
The Regulatory Requirement for Testing is detailed in 49 Code of Federal Regulations (CFR) 173.56 requires that “new explosives” must be examined and approved before they can be transported in commerce. A “new explosive” means an explosive produced by a person who “(1) Has not previously produced that explosive; or (2) Has previously produced that explosive but has made a change in the formulation, design or process so as to alter any of the properties of the explosive.” Each manufacturer must have its explosive or explosive device examined and approved. Each person requesting approval of a new explosive must submit a copy of a recommended hazard class issued by one of the approved laboratories cited in 173.56 and must receive written approval and an EX-number from the Associate Administrator for Hazardous Materials Safety before offering that explosive for transportation and enabling the use for mine blasting by MSHA.
A specific series of tests determines the hazard classification. Zukovich, Morhard & Wade, LLC will prepare a report with recommendations for approvals as expert knowledge of the material can, in some cases, substitute for some of the tests in this process.
The classification document assigns an EX-number and provides the United Nations classification name, number, compatibility group, and serves as a competent authority approval needed when shipping under international regulations.
Competent Authority Approvals
Competent Authority Approvals are documents issued to 49 CFR, International Civil Aviation Organization Regulations and the International Maritime Dangerous Goods Code. The documents can provide classification information only or provide stipulations on how to package, mark, test and/or a variety of other special provisions to follow when shipping domestically or internationally.
This comes from the competent authority which, in the United States, resides with the office of Associate Administrator for Hazardous Materials Safety, Research and Special Programs of US DOT. It acts on recommendations from a restricted list of explosives testing laboratories. These recommendations are based on test results and analogy with existing explosives.
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