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Interpretation Response #05-0309 ([AMCOM, U.S. Army Garrison] [Mr. Richard E. Eads])

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

Interpretation Response Details

Response Publish Date:

Company Name: AMCOM, U.S. Army Garrison

Individual Name: Mr. Richard E. Eads

Location State: AI Country: US

View the Interpretation Document

Response text:

Jun 23, 2006


Mr. Richard E. Eads                        Reference No. 05-0309
Quality Assurance Specialist
Ammunition Surveillance (QASAS)
AMCOM, U.S. Army Garrison
Redstone Arsenal, Al 35898-5000

Dear Mr. Eads:

This is in response to your letter requesting clarification on the correct display of placards on the front of a tractor-trailer motor vehicle under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask if the placard must appear on the front of the truck’s tractor or if it may appear on the front of its trailer. We apologize for the delay in responding and any inconvenience this may have caused.

When placarding is required by § 172.504(a) of the HMR, a transport vehicle must be placarded on each side and each end. The HMR require a placard to be clearly visible from the direction it faces, except from the direction of another transport vehicle to which it is coupled (see § 172.5 16(a)). For purposes of the HMR, a “transport vehicle” is a cargo-carrying vehicle, such as a van, tractor, trailer, semi-trailer, tank car, or rail car used for the transportation of cargo by any mode. Each cargo-carrying body is a separate transport vehicle. Thus, in the example you cite of a truck tractor with a flatbed trailer, a placard is not required on the front of the truck tractor if the flatbed trailer is placarded on each side and each end, even if the placard on the front of the flatbed trailer is riot visible.

We appreciate your concern that the exception in § 172.516 could have implications for emergency responders at an accident scene. We considered this issue, that is the visibility of the front placard on the trailer being obscured by the attached tractor, in an advance notice of proposed rulemaking published under Docket: No. HM-206 (57 FR 24532, June 9, 1992). Based on the comments received in response to the AN] stating revisions to the placard visibility requirements were not necessary, we proposed no revisions in the notice of proposed rulemaking (Docket No. HM-206, 59 FR 41848, August 15, 1994).



Hattie L. Mitchell, Chief
Regulatory Review and Reinvention
Office of Hazardous Materials Standards

172.504, 172.516

Regulation Sections

Section Subject
172.504 General placarding requirements
172.516 Visibility and display of placards