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Interpretation Response #09-0055 ([MCSAP, Troop I, Olathe] [Mr. Rex Railsback])

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

Interpretation Response Details

Response Publish Date:

Company Name: MCSAP, Troop I, Olathe

Individual Name: Mr. Rex Railsback

Location State: KS Country: US

View the Interpretation Document

Response text:

April 6, 2009




Mr. Rex Railsback

MCSAP, Troop I, Olathe

1220 S. Enterprise

Olathe, KS 66061

Ref. No. 09-0055

Dear Mr. Railsback:

This responds to your March 12, 2009 letter requesting clarification of the requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 100-185) applicable to the visibility and display of placards. Accompanying your letter are photographs of a Sterling straight truck with clearly visible placards mounted on the front of the cargo railing. Specifically, you ask whether the placarded vehicle, as depicted in the photographs, satisfies the requirements of

§§ 172.504 and 172.516.

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 § 172.516(a)). For purposes of the HMR, a "transport vehicle" is a cargo-carrying vehicle such as an automobile, van, tractor, truck, semi-trailer, tank car or rail car used for the transportation of cargo by any mode.

In this specific case, the placards on the front of the cargo-carrying portion of the transport vehicle are clearly visible from the direction they face, and comply with the requirements of

§§ 172.504(a) and 172.516(a). Generally, placards on the sides and ends of the cargo-carrying portion of a vehicles cargo body satisfy requirements for placarding the sides and ends, even if they are not located at the outer perimeter of the vehicle, as long as they are readily visible and not obscured by appurtenances in the direction they face. In order to clarify this issue more thoroughly, we may address this in a future rulemaking.

I trust this satisfies your inquiry. Please contact us if we can be of further assistance.



Edward T. Mazzullo

Director, 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