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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 #06-0108 ([Con-way] [Mr. Robert Petrancosta ])

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

Interpretation Response Details

Response Publish Date:

Company Name: Con-way

Individual Name: Mr. Robert Petrancosta 

Location State: MI Country: US

View the Interpretation Document

Response text:

May 30, 2006


Mr. Robert Petrancosta                 Reference No. 06-0108
Director, Safety and Environmental Compliance
1.10 Parkland Plaza
Ann Arbor, MI 48103

Dear Mr. Petrancosta:

This is in response to your letter and subsequent conversations with Del Billings concerning the placement of placards on a vehicle under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You provided a description and photographs of a placard holder on the side of a transport vehicle. The placard holder is positioned on top of multi-colored stripes that run horizontally along the trailer. You ask if the location of the placard, as described and shown in the photographs, is in compliance with the HMR.

It is the opinion of this Office that the placement of the placards over the horizontal stripes as described in your letter and shown in your photographs is not a violation of the HMR. In accordance with § 172.502(a)(2), it is prohibited to affix or display any sign, advertisement, slogan, or device that, by its color, design, shape or content, could be confused with any placard prescribed in Part 172, Subpart F. The painted stripe is not a sign, advertisement, slogan, or device and could not be confused with a placard. Additionally, the placard must be displayed away from any marking (including advertising) that could substantially reduce its effectiveness (see § 172.5 16(c)(4)). The painted stripe is seen as a background color rather than a marking and does not substantially reduce the effectiveness of the placard and; therefore, is permissible. Finally, in the event a placard shares the same color as a part of the horizontal striped background, a dotted or solid line outer border may be used when needed to provide contrast with the background color (see § 172.5 19(b)(2)).

I hope this satisfies your request.



Charles E. Betts
Senior Transportation Specialist
Office of Hazardous Materials Standards

172.502(a)(2), 172.516(c)(4)

Regulation Sections

Section Subject
172.502 Prohibited and permissive placarding
172.516 Visibility and display of placards