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Interpretation Response #04-0132 ([International Association of Fire Chiefs] [Chief Ernest Mitchell])

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

Interpretation Response Details

Response Publish Date:

Company Name: International Association of Fire Chiefs

Individual Name: Chief Ernest Mitchell

Location State: VA Country: US

View the Interpretation Document

Response text:

Jun 15, 2004


Chief Ernest Mitchell                Reference No. 04-0132


International Association of Fire Chiefs

4025 Fair Ridge Drive

Fairfax, VA 22033-2868

Dear Chief Mitchell:

This responds to your May 7, 2004 letter addressed to the Honorable Thomas J. Ridge, Secretary, U.S. Department of Homeland Security (DHS), with a copy to the Secretary of Transportation Norman Y. Mineta, expressing your strong support for maintaining the use of the current hazard warning placards for shipments of hazardous materials until a replacement system has been demonstrated to be effective and the fire service has been trained in its use. Your letter was referred to me for response.

As you know, in response to concerns that placards could be used by terrorists or criminals to identify potential targets, the Research and Special Programs Administration (RSPA) on January 15, 2003, completed a study of the role placards play for transportation safety and security. The study took into account the views of all stakeholders, including IAFC, through working group meetings. The study concluded that the existing placarding system should be retained, but that we should continue to review the use of alternatives to placards in specific high-risk situations, as well as for broad application. In considering potential changes to the placarding requirements as part of its continuing review, the study further concluded that we should consider the impact on costs, training and international trade that could result from changes in the current placarding requirements. (The study can be found on our website at

In addition, the DHS is conducting a study to examine alternative methods for communicating the hazards of hazardous materials transported in rail tank cars. The study will identify 10 alternatives to placarding for communicating hazards and will include operational testing of the alternatives identified. The evaluation of the alternatives will include: (1) technical considerations, such as the speed and accuracy of the systems and the interoperability of the systems with those currently in use by the emergency response community; (2) international transportation issues, such as the impact on international rail transportation between the United States and Canada and Mexico; (3) the costs associated with the alternatives, including installation, start-up, and system maintenance costs, as well as cost of training the users, showing particular consideration of small urban and rural volunteer first responders; and (4) the speed with which the alternatives can be implemented, including the time required to train first responders to use the new technology. DHS expects to complete the study by the end of 2004.

Effective hazard communication is critical to the ability of emergency response personnel to handle transportation accidents involving hazardous materials. Let me assure you that DOT will propose no change to the current placarding system without careful consideration of all the potential impacts, especially the potential impacts on emergency response and those responsible for planning for and responding to hazardous materials transportation accidents.

Thank you for your letter. Please feel free to contact me if you have questions or need additional information.



Frits Wybenga

Deputy Associate Administrator

Office of Hazardous Materials Safety

172.500,  172.800

Regulation Sections

Section Subject
172.500 Applicability of placarding requirements
172.800 Purpose and applicability