Interpretation Response #02-0263 ([CHS Cooperatives] [John R. Macpherson])

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

Interpretation Response Details

Response Publish Date: 03/02/2003

Company Name: CHS Cooperatives

Individual Name: John R. Macpherson

Location State: IA Country: US

View the Interpretation Document

Response text:

Mar 02, 2003

Mr. John R. Macpherson                  Reference No. 02-0263
Corp. QC Manager
CHS Cooperatives
16682B 245th Street
Mason City, IA  50401

Dear Mr. Macpherson,

This is in response to your September 23, 2002, letter regarding placarding requirements on a cargo tank motor vehicle under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you ask based on the photographs you provided, if you are in violation of 172.516(c)(4).

The placards and markings shown in the provided photographs are not in violation of § 172-516(c)(4).  Section 172.516(c)(4) states that the placard must be located away from any markings (such as advertising) that could substantially reduce its effectiveness and in any case at least 3 inches (76.0mm.) away from such marking.  The markings displayed next to the placards in the submitted photographs are required by § 172.328 and Special Provision 13.  Therefore, § 172.516(c)(4) is not applicable to these markings.

I hope this satisfies your request.

Sincerely,

John A. Gale
Transportation Regulations Specialist
Office of Hazardous Materials Standards

172.516

Regulation Sections