Definition of Large Article
Pipeline and Hazardous Materials Safety Administration · Oct 23, 1995 · Reference No. 95-0183
Interprets: 49 CFR § 173.62(d)
Reggie’s quick take
A company that ships explosives asked what counts as a "large article" under exception 49 in § 173.62(d), which lets certain items move unpackaged. The agency said a large article is an item that cannot practically be put in the required UN performance-oriented packaging because of its size, weight or shape. Under that test, a 330-pound bomb and an 800-pound bomb qualify, but grenades do not.
Written by AI (Claude) on Oct 22, 2026. Robots make mistakes and leave things out, so the letter below is what counts. Not legal advice.
This is in response to your letter dated June 26, 1995, regarding the definition of a "large article" as that term is used in the Table of particular packaging requirements, or exception number 49 in 49 CFR 173.62(d).
Particular packaging requirements or exceptions number 49 in § 173.62(d) allows a "large article", without its means of initiation or with its means of initiation but containing at least two effective protective features, to be transported unpackaged. It is our opinion that a large article is a item that cannot practically, because of its size, weight or shape, be packaged in the required UN performance oriented packaging. The explosive item described in your letter as a 330 pound bomb and the explosive item described as 800 pound bomb are "large articles." However, the grenades described in your letter are not large articles.
A letter of interpretation applies the regulations to the facts the requester described. It isn’t a regulation and isn’t legal advice. The agency’s copy.