Interpretation Response #06-0130

Interpretation Response Details

Jun 16, 2006

Mr. Richard D. Kaczynski                Reference No. 06-0130
Safety Manger
A Duie Pyle Companies
P.O. Box 564
West Chester, PA 19381

Dear Mr. Kaczynski:

This is in response to your letter requesting clarification of the placarding requirements located in § 172.506 of the Hazardous Materials Regulations (FIMR; 49 CFR Parts 171- 180). Specifically, you ask if an offeror is required to verify that the carrier’s vehicle is properly placarded prior to leaving his facility. You indicate, that under § 172.506 it is the offeror’s responsibility to furnish placards to the carrier and the carrier’s responsibility to affix those placards to the transport vehicle.

Under § 172.506(a) each person offering a motor carrier a hazardous material for transportation must provide the motor carrier the required placards for the material being offered prior to or at the same time the material is offered for transportation. The HMR do not specify when placards must be applied to or removed from a motor vehicle. However, § 172.506(a)(1) specifically states that no motor carrier may transport a hazardous material in a motor vehicle unless the placards required for the hazardous material are affixed thereto. Therefore, if the offeror provides the required placards, it becomes the motor carrier’s responsibility to affix those placards or, if other hazardous materials are already on the motor vehicle, the placards required by Part 172, Subpart F.

I hope this information is helpful. Please contact us if you require additional assistance.

Sincerely,

John A. Gale
Chief, Standards Development
Office of Hazardous Materials Standards

172.506

Regulation Sections