Interpretation Response #04-0164 ([Southern Service Center] [Mr. Charles Phillips])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Southern Service Center
Individual Name: Mr. Charles Phillips
Location State: GA Country: US
View the Interpretation Document
Response text:
Aug 6, 2004
Mr. Charles Phillips Reference No. 04-0164
Southern Service Center
61 Forsyth Street, S.W., Suite 17T75
Atlanta, GA 30303
Dear Mr. Phillips:
This is in response to your July 21, 2004 letter concerning placarding requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether a placard displayed on the front of a cargo body, but behind the drivers compartment of the transport vehicle, satisfies the requirement for visibility and display of placards in § 172.516.
You state the truck-tractor and cargo body make up a single transport vehicle. In addition, you included a picture of the placard on the front of the cargo body, which is obscured by the driver’s compartment of the vehicle. Each placard on a motor vehicle must be visible from the direction it faces, except from the direction of “another transport vehicle” to which the motor vehicle is coupled (172.516). In this case, the truck-tractor is not “another transport vehicle,” because it is part of a single transport vehicle. Therefore, the obscured placard does not meet the visibility requirement in § 172.516. A placard placed on the front of the truck-tractor in accordance with § 172.516(b) would satisfy the visibility requirement of § 172.516(a).
I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.
Sincerely,
John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards
172.516
Regulation Sections
| Section | Subject |
|---|---|
| 172.516 | Visibility and display of placards |