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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 #07-0071 ([PCS Sales, (USA) Inc] [Ms. Tracey G. Smith])

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

Interpretation Response Details

Response Publish Date:

Company Name: PCS Sales, (USA) Inc

Individual Name: Ms. Tracey G. Smith

Location State: IL Country: US

View the Interpretation Document

Response text:

Apr 27, 2007


Ms. Tracey G. Smith              Reference No. 07-0071
PCS Sales, (USA) Inc.
1101 Skokie Boulevard. Suite 400
Northbrook, IL 60062

Dear Ms. Smith:

This is in response to your March 29, 2007 letter regarding placarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask where on a transport vehicle a subsidiary hazard placard must be placed in relation to the primary hazard class placard with which it is associated.

The HMR do not specify where the subsidiary hazard class placard must be placed in relation to the primary hazard class placard (i.e., above, below, to the left or right). Subsidiary hazard placards, when required under § 172.505, must be placed on each side and each end of the transport vehicle, freight container, portable tank, unit load device, or rail car. In addition, the requirements for visibility and display of placards in § 172.516 apply to placards representing both primary hazards and subsidiary hazards.

I hope this information is helpful. If you have further questions, please do not hesitate to contact this office.



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

172.505, 172.516

Regulation Sections

Section Subject
172.505 Placarding for subsidiary hazards
172.516 Visibility and display of placards