Interpretation Response #25-0105
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Trophy Trucking Services, LLC
Individual Name: Matt Ramirez
Location State: TX Country: US
View the Interpretation Document
Response text:
December 9, 2025
Matt Ramirez
West Texas Regional Safety Manager
Trophy Trucking Services, LLC
100 Glenborough Drive
Suite 408
Houston, TX 77067
Reference No. 25-0105
Dear Mr. Ramirez:
This letter is in response to your July 25, 2025 email requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to visibility and display of placards. You described a scenario and provided photographs of a pickup truck equipped with a gooseneck hitch,1 also known as a neck-over hitch, and used to tow a trailer (i.e., a cargo body) carrying hazardous materials. All hazardous materials are loaded onto the trailer and placards are affixed on both sides and rear of the trailer. The forward-facing placard is affixed to the front bumper of the pickup truck. Furthermore, you seek clarification of previously issued letter of interpretation Reference No. 16-0166R2 with respect to reference to a "fifth wheel" and a pickup truck equipped with a ball and hitch. Specifically, you ask if a pickup truck with a gooseneck hitch would be considered a "truck-tractor"3 for purposes of displaying a placard on the front of the motor vehicle as prescribed by §§ 172.504(a) and 172.516(b).
1 A gooseneck hitch is a truck bed hitch that connects to a gooseneck trailer using a hitch ball.
2 https://www.phmsa.dot.gov/regulations/title49/interp/16-0166r.
3 A truck-tractor is a self-propelled commercial motor vehicle designed and/or used primarily for drawing other vehicles.
Yes. Based on the information and photographs provided, the pickup truck with the gooseneck hitch may be considered a "truck-tractor" for purposes of § 172.516(b). Therefore, the required placarding for the front of the motor vehicle may be on the front of the pickup truck instead of or in addition to placarding on the front of the trailer (i.e., the cargo body).
I hope this information is helpful. Please contact us if we can be of further assistance.
Sincerely,
Dirk DerKinderen
Chief, Standards and Development Branch
Standards and Rulemaking Division
§ 172.504(a), § 172.516(b)