Appleton, Wisc. The U.S. Department of Transportation, Office of Special Permits and Approvals, is in the process of making changes to the current EX Application form. Although the new application form should be publicly available in the near future, the January 1, 2007 effective date is approaching fast. Therefore, a prudent businessman is best served by understanding the scope of the changes to be made. The changes can be separated into the following three categories; (i) particle size, (ii) point of contact and (iii) U.S. Agent.
Particle Size
In addition to the information already subject to disclosure, after January 1, 2007, all applications for EX numbers must also include a detailed description of the particle size (as opposed to mesh size) for any and all metallic chemical compositions listed in the device. Although at the time of this writing the DOT had yet to determine the required standard measurement of ‘particle size’, conversion tables are widely used to perform this calculation.
Point of Contact
In addition to the current requirements regarding point of contact, the DOT will also require the disclosure of the email address of the point of contact.
U.S. Agent
Foreign companies will now be required to provide contact information regarding their designated U.S. Agent; the full name, address, telephone and fax numbers, as well as an email address.
Although not falling into any of the preceding three categories, the application will also include a refined field of information relating to reloadable devices. Going forward, if the device is reloadable you will be required to disclose the number of shells in each kit, the composition weight of each shell, the aggregate weight of all shells, and the specific number of launching tubes. While in all likelihood the number of tubes will remain one the DOT wants to be informed should the kit include more than one tube. With respect to reports, the application will request the disclosure of the number of reports, and the total weight of the report(s).
I am filing this article from Appleton, Wisconsin, the site of the PGI 2006 Convention. The dedication and professionalism exhibited by the members of this organization is impressive, and I would be remiss not to extend a heartfelt thank you to Dr. John R. Steinberg, Industry and Regulatory Representative, Media Relations. The PGI members and its Executive Board are a class act, and I am proud to be a member (I can only hope the feeling is mutual).
