Packaging Requirements for Smokeless Powder
Pipeline and Hazardous Materials Safety Administration · Jan 31, 1997 · Reference No. 97-0185
Interprets: 49 CFR § 173.171
Reggie’s quick take
Someone asked whether the 16 pound limit in § 173.171(d) for smokeless powder also applies to packagings under § 173.171(a), (b) and (c). PHMSA says no. The 16 pound limit applies only to packagings authorized under § 173.171(d). That section allows different inner packagings of tested combination packagings to be mixed together without more testing, but only in a 4G fiberboard box that meets Packing Group I performance, with inner containers packed to prevent movement and a total net weight of 16 pounds or less.
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 October 2, 1996, regarding the packaging requirements for smokeless powder in 49 CFR 173.171. Specifically, you ask if the 16 pound weight limitation in 49 CFR 173.171(d) also applies to 49 CFR 173.171(a), (b) and (c).
The 16 pound weight limitation in 173.171(d) applies only to those packagings authorized under § 173.171(d) and does not apply to those packagings authorized under § 173.171(a), (b) or (c). Section 173.171(d) authorizes the intermixing of different inner packaging of tested and approved combination packagings with no further testing provided: (1) a 4G fiberboard packagings meeting the Packing Group I performance level is used; (2) all inside containers are packed to prevent movement; and (3) the total net weight of smokeless powder in one package does not exceed 16 pounds. In addition, several packages meeting the conditions of § 173.171(d) may be overpacked together if the 100 pound net mass limitation in § 173.171(b) is not exceeded.
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.