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U.S. Department of Transportation U.S. Department of Transportation Icon United States Department of Transportation United States Department of Transportation

Interpretation Response #02-0211 ([Minnesota Department of Transportation, Office of Motor Carrier Services] [Michael Ritchie])

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

Interpretation Response Details

Response Publish Date:

Company Name: Minnesota Department of Transportation, Office of Motor Carrier Services

Individual Name: Michael Ritchie

Location State: MN Country: US

View the Interpretation Document

Response text:

Sep 30, 2002

Mr. Michael Ritchie                 Reference No. 02-0211
Minnesota Department of Transportation
office of Motor Carrier Services
1110 Centre Pointe Curve, Mail Stop 420
Mendota Heights, MN 55120

Dear Mr. Ritchie:

This is in response to your letter dated August 19, 2002, requesting clarification of the prohibited placarding provisions.  Specifically, you ask if white or orange placard holders, when placed on a contrasting background, would be prohibited under § 172.502(a)(2) of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  You enclosed several photographs of white and orange placard holders.

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 placard is prohibited under § 172.502(a)(2). This prohibition is intended to limit the potential for dilution of the hazard warning communication that would be provided by an appropriate hazardous materials placard.  Based on our review of the photographs that you provided, it is our opinion that the orange placard holders that are affixed to a contrasting background, as depicted in your enclosures, could be confused by color, design and shape with an explosive placard.  Therefore, the orange placard holders shown on a contrasting background are prohibited under 172.502(a)(2). The white placard holders that are affixed to a contrasting background, as depicted in your enclosures, are not prohibited under 172.502(a)(2).

It is our opinion that neither the white placard holders nor the orange holders displayed on an orange background would be confused with, or mistaken for, a hazard warning placard and, therefore, neither is prohibited under 172.502 (b)(2).

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

Sincerely,

Edward T. Mazzullo
Director, Office of Hazardous
 Materials Standards

172.502

Regulation Sections

Section Subject
172.502 Prohibited and permissive placarding