Define Dromedary

1. PHMSA has used the word \"dromedary\" in multiple interpretations to include the phrase \"crush proof box\". 2. The SLP-22 instructions conflict with the HMR; whereas, Table 2 of the SLP-22 instructions indicate there's no limit on the number of detonators and Part 173.63 states 1,000 detonators per package. 3. Contractors operating vehicles with US Government plates are subject to the HMR/FMCSR. Many inspectors are flagging Government owned equipment with a US DOT number through scales without considering the vehicle/driver for inspection. The misconception has allowed regulated motor carriers to avoid roadside inspections and avoid generation of CSA inspection data.

1. Some explosive transporters are declaring IME SLP-22 containers as dromedaries when the explosives being transported exceed the SLP-22 container specifications and exceed the parameters of 49 CFR Part 173.63, i.e. more than 1 gram of explosives per detonator. 2. Part 171.7 Incorporation by Reference allows use of documents incorporated by reference when the HMR does not have specific instructions; therefore, when documents incorporated by reference conflict with the HMR they do not apply. 3. The lack of inspection data on Government contractors makes it difficult for Government agencies to acquire a snapshot of contractors' practices.

1. PHMSA should define \"dromedary\" and list specifications in Part 178. 2. Inspectors need to be aware of the conflicts between SLP-22 and Part 173.63. 3. Inspectors should be reminded of the applicability of the HMR/FMCSR to Government owned equipment operated by civilian contractors who are not \"employees\" of the Government.