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Interim Hazard Classification Process
UNITED STATES ARMY Interim Hazard Classification Process As of February 2017 Conducted by U.S. Army Defense Ammunition Center U.S. Army Technical Center for Explosives Safety
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AGENDA Purpose References
What are Interim Hazard Classifications (IHC)? What is Department of Transportation (DOT) Special Permit (SP) 15448? Who are the IHC Authorities? (Hazard Classifiers) When are IHCs issued? Munitions History Program (MHP) Questions
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Purpose The purpose of this presentation is to provide basic
knowledge and understanding of what IHCs are, when they are used and how to request an IHC through the Munitions History Program (MHP). Intent is to provide basic understanding in IHCs. What are they? When are they used? How are they obtained? By the end of this presentation, those questions should be answered.
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References 49 CFR Parts 100-185 DoD Directive 6055.9E DoDM 6055.09M
NATO STANAG 4123 (Methods to Determine and Classify the Hazards of Ammunition and Explosives) UN Recommendations on Transportation of Dangerous Goods and Manual of Tests and Criteria Test Methodologies Harmonized with Insensitive Munitions (IM) Requirement TB 700-2 DEPARTMENT OF DEFENSE AMMUNITION AND EXPLOSIVES HAZARD CLASSIFICATION PROCEDURES 30 JULY 2012 Listed are the governing regulations implementing the requirements of Department of Transportation (DOT).
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What are IHCs? Interim Hazard Classification (IHC) is a mechanism allowed by the Department of Transportation (DOT) for the movement of Ammunition used by the Department of Defense (DOD) and its Contractors when Final Hazard Classification (FHC) has not been completed. FHCs are issued after meeting requirements outlined in TB Tri-service concurrence and DDESB concurrence is required for FHC. An IHC is a Memorandum which describes the item, Net Explosive Weight (NEW) and a temporary Hazard Classification which allows Ammunition and Explosives (AE) item to be shipped and stored. An IHC is valid for DoD storage worldwide, for domestic transportation, and for international transportation by a military carrier. IHCs are GRANTED by signature by designated personnel . TB 700-2, paragraph 3-6 provides the requirement for IHC signature authorities and identifies the Offices with IHC authority. Next slide covers the offices with IHC authority
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What is DOT-SP 15448? Special permit authorizes the transportation in commerce of certain Class 1 materials under an Interim Hazard Classification. Special Permit sets forth alternative requirements, or variances, to the requirements in the HMR (49 CFR). DOT-SP is written consent that relieves DOD from some regulatory requirements set forth in 49 CFR by authorizing use of an IHC. This permit cites the regulation from which DOD is exempted in paragraph 4.
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What is DOT-SP 15448? Special permit authorizes USATCES as the IHC approval authority and authority to delegate IHC approval
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Who are the IHC Authorities?
TB 700-2, Table 3-3, identifies the Offices with IHC authority. US Army Technical Center for Explosives Safety (USATCES) is the Army’s signature authority. Although NOT listed on this slide, Department of Energy is the 4th office with signature authority. In Table 3-4, additional IHC authorities are identified that were delegated from each of the services. The offices delegated are listed below the services. - AMCOM - AMRDEC - ARDEC - ARL - ECBC
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When are IHCs issued? Items in the development phase
End of item life cycle, components or items shipped for demil Foreign ammunition and explosives exploitation Final Hazard Classification (FHC) is in process Items not procured through the Army Supply System In slide 5, FHCs was introduced. Again, DOT requires all dangerous goods have a final hazard classification based on tests conducted on the item in its packaging. Its actually the packaging (item inside) that must provide certain levels of protection as specified IAW 49CFR. These standards are required to meet international requirements as well. In those cases where testing has not been completed, or item is in developmental phase, or item is foreign/nonstandard and not procured through the Army Supply System or has not gone through the Final Hazard Classification process, IHCs are authorized for transportation in commerce IAW DOT Special Permit (Slide 8 is copy of the DOT Special Permit 15448 IHC are normally valid for one year for transportation purposes, but may be issued for a reduced period, or up to two years, with justification provided. They are valid for DOD storage purposes until replaced by a new IHC or a FHC.
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What are minimum requirements for an IHC?
TB Materials test UN SERIES 3 OR UN SERIES 4 (Supporting data that concludes AE is not forbidden for transportation) To support an IHC other Than HD 1.1 more test data may be needed At a minimum, UN SERIES 3 or UN SERIES 4 test results are required for an IHC. If test results are not available, a statement of the rationale supporting the conclusion that the AE is not forbidden for transportation must be provided. UN SERIES 3 tests are conducted to answer the question “Is the substance thermally stable and is the substance too hazardous for transportation?” UN SERIES 4 tests are conducted to answer the question “Is this AE, packaged AE or packaged substance too hazardous for transport?” Additional hazard classification test data may be required to support an IHC other than HD 1.1. Additional tests will be dependent on the AE configuration. Analogies to existing AE with FHC may be used for assigning IHC. Next slides discuss additional technical data that is required for IHC.
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What are minimum requirements for an IHC?
Battlefield AE pickups needing an IHC but missing technical/descriptive data and test data? IHC Authority may issue IHC provided qualified personnel (EOD) have evaluated and determined safe to ship by assessing: - electrostatic/electromagnetic influence - effects of environmental exposure - mechanical defects - rough handling/vibration Conservative Hazard Classification assigned Foreign munitions of unknown pedigree and often times unknown condition collected from field recovery or battlefield, will be shipped to the US for testing. There are instances where munitions will just be stored and shipped at a later date. Regardless, an IHC is still required IAW TB and DA PAM The first step in dealing with foreign munitions or nonstandard munitions needing IHCs is to identify the nature of the hazards involved in order to qualify the munition for shipment/storage. It is difficult to know exact NEWs and explosive compositions of these foreign munitions. IAW TB and AFMAN , captured or unknown munitions are required to have EOD Safe-to-Ship certification. EOD evaluates and determines safe-to-ship by assessing electromagnetic influences, environmental exposures, mechanical defects. Slide 12 is an example of an EOD certification that is supporting documentation for assigning hazard classifications.
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What are minimum requirements for an IHC?
An example of an EOD certification. Certification meets the requirements outlined in 49 CFR and AFMAN
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What are minimum requirements for an IHC?
IAW TB 700-2, paragraph 3-5f, technical data is required for IHC. Organizations generate local worksheet form that includes required technical data. Next slide is an example of a locally generated worksheet.
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What are minimum requirements for an IHC?
Missing critical data may result in the following Hazard Classifications? 1.1L 1.1F MOST CONSERVATIVE A locally generated worksheet. The red highlighted items are the most critical data needed for IHCs. There are some instances in which the critical data is not available (e.g. explosive composition, net explosive weight); however, hazard classification can be still be assigned but will typically result in the most conservative hazard class of 1.1F or 1.1L. These conservative hazard classifications require a lot of storage space to be able to comply with explosives safety quantity distance requirements and DOT requirements so it is essential to provide all data elements to ensure proper classification. This leads into Slide 11, generating IHCs for battlefield pick-ups (foreign munitions). More data results in a more accurate Hazard Classification
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Munitions History Program (MHP)
Army IHCs reside within MHP, therefore, to obtain or request IHCs, an MHP account is needed. All new MHP users must submit a registration request. To do this, log in at A CAC, ECA, or PKI certificate is required to access the website. Registration process is covered in the MHP course that is available online. Slide 14 discusses MHP course. MHP Website-
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Munitions History Program (MHP)
Distance learning training is available through ALMS. Register through ATRRS using course number 4E-F64/645-F48 (formerly AMMO-97-DL) Register at https//: All new MHP users are encouraged to register for the online MHP training that is available through ALMS. Register through ATRRS using course number 4E-F64/645-F48 (formerly AMMO-97-DL). Course provides extensive information to successfully navigate within the MHP website. Course covers how to register for an MHP account, how to determine the type of profile needed to suit or tailor your needs within MHP. Registration information is also available through the FAQ on the Help tab in MHP.
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Munitions History Program (MHP)
Highlight the DAC tab to expand drop-down menu. Highlight IHC selection to expand drop-down to make final selection. Steps in navigating to the IHC module. Depending upon MHP permissions granted to a user, drop-down menu will vary. Users are required to have permission to access the IHC module to be able to submit/request IHCs. Arrows highlight the DAC tab that expands the drop-down meu. Drop-down displays 5 categories to select from. Selecting the IHC tab will expand another drop-down menu for user make a selection from 3 options depending upon what user needs. In this example, step-by-step procedures for requesting/submitting a new IHC will be given in the next slides, After highlight IHC, select “Request New IHC” from the drop-down menu.
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Munitions History Program (MHP)
For all new requests, data elements must be provided. These are the same data elements that were discussed in slides 9 and 10. Slide 10 was the example of a worksheet generated by the requester to facilitate data transfer to MHP. The “Red Boxed” items highlight those data elements that are critical for assigning hazard classification. Missing data elements will result in more conservative hazard classification as discussed in previous slide 14. Next slide continues with further details in completing IHC request process.
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Munitions History Program (MHP)
Additional information needed to complete IHC request process. UN Number (Orange Arrow) has drop-down menu of the United Nations Serial Number. The Hazard Class/Div is auto-populated after selecting UN Number. The “Special Instructions” block (Light Blue Arrow) is generally used for additional packaging instructions. These comments are applied to the final IHC Memorandum. The “IHC access” (Dark Red Arrow) is the requestor’s option to allow their IHC to be public or remain out of the public sector. Selecting “Public” will allow MHP users with IHC permission to access IHC without any authorization from the IHC owner. Selecting “Organization” requires authorization from IHC owner to release IHC. Slide 23 illustrates the difference. “Add Document”(Red Arrow). All supporting documents, worksheet, EOD certification, photos can be uploaded. In the “Comment” block (Black Arrow), user is able provide comments or notes to the reviewer. These comments remain outside of public viewing.
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Munitions History Program (MHP)
Example of a completed request. Comments in special instruction block and comment block were provided for instructional purposes. User will select either “Save as Draft” or “Submit IHC Request”. Selecting to save as a draft, the IHC will remain in the draft queue until it is submitted for review. IHC is only visible to the person preparing the IHC request.
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Munitions History Program (MHP)
After selecting “Submit IHC Request”, IHC is now PENDING in the Reviewer’s queue. “Red Circle” illustrates the pending for review status. “Yellow” highlighted boxes illustrate the “Special Instruction” block and the “Comment” block. To reiterate, comments inserted in the “Special Instruction” block will be populated to the final IHC memo. Comments that were entered from the previous example are in red text in “Comments” block. In addition, the date/time reflects when the IHC was submitted and the name of requester.
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Munitions History Program (MHP)
“Red Circle” reflects IHC in Reviewed status. “Yellow Box” illustrates the date/time of when IHC was reviewed and the reviewer’s name. Comments made from the reviewer are in red text.
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Munitions History Program (MHP)
“Red Circle” reflects IHC is signed. “Yellow Box” illustrates the date/time of when IHC was signed and the signee’s name. Comments made from signee are in red text.
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Munitions History Program (MHP)
“Yellow Box” highlights IHC example as it appears from the IHC list. In this example, IHC was made public. This allows anyone with IHC permissions to access and view the IHC. “Red Box” highlights IHCs that is not available to the public and it must be requested to view. When there is a request to view the IHC, the request goes directly to the USATCES IHC team. Depending upon which organization owns the IHC will determine what POC will respond to that request. As mentioned in slide 16, depending upon what IHC access is selected, Public or Organization, will determine how IHC will be available.
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Munitions History Program (MHP)
Example of signed IHC. Yellow blocks indicate the reviewer’s POC and the signee’s POC. The Red arrow illustrates the “Special Instructions” that the requestor submitted in Slide 19.
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QUESTIONS
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