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Interpretation Response #00-0101 ([Mayer, Brown & Platt] [Mr. Philip R. Recht])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: Mayer, Brown & Platt

Individual Name: Mr. Philip R. Recht

Location State: CA Country: US

View the Interpretation Document

Response text:

May 5, 2000


Mr. Philip R. Recht                           Reference No. 00-0101
Mayer, Brown & Platt
350 South Grand Avenue, 25th Floor
Los Angeles, CA 90071-1503

Dear Mr. Recht:

This is in response to your letter dated April 3, 2000, requesting whether your client's “NationsRent, Inc.” logo used on its commercial vehicles is prohibited under Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  You enclosed an example of the logo.

Displaying or affixing a sign, advertisement, slogan, or device on a transport vehicle or freight container that, by its color, design, shape, or content, could be confused with, or mistaken for, a hazard warning label or placard is prohibited under §§172.401(b) and 172.502(a)(2)). This prohibition is intended to limit the potential for dilution of hazard warning communication provided by the appropriate hazardous materials labels and placards.  Based on our review, it is our opinion that the “NationsRent, Inc.” logo, as shown in your enclosure, is sufficiently distinct from a placard referenced by the HMR.  Therefore, this logo is not prohibited under the provisions of §§ 172.401(b) and 172.502(a)(3).

I hope this satisfies your inquiry.  If we can be of further assistance, please contact us.



Edward T. Mazzullo
Director, Office of Hazardous
 Materials Standards


Regulation Sections

Section Subject
172.502 Prohibited and permissive placarding