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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 #09-0120 ([Fleet Safety Services, Inc] [Mr. Gary LaBreck])

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

Interpretation Response Details

Response Publish Date:

Company Name: Fleet Safety Services, Inc

Individual Name: Mr. Gary LaBreck

Location State: MA Country: US

View the Interpretation Document

Response text:

April 1, 2010




Mr. Gary LaBreck

Fleet Safety Services, Inc

12 Harvard Street

Worcester, MA 01609

Ref. No. 09-0120

Dear Mr. LaBreck:

This responds to your letter requesting clarification of the placarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). Specifically, you ask whether a pickup truck towing a trailer is considered two separate transport vehicles for the purposes of placarding under the HMR. Your client intends to transport less than 1,001 lbs aggregate gross weight of non-toxic compressed gases in both the pickup truck and the trailer where the total aggregate gross weight of cylinders in both cargo-carrying bodies exceeds 1,001 lbs.

As you are aware, § 171.8 of the HMR defines a transport vehicle as "a cargo-carrying vehicle such as an automobile, van, tractor, truck, semitrailer, tank car or railcar used for the transportation of cargo by any mode. Each cargo-carrying body (trailer, rail car, etc.) is a separate transport vehicle." Additionally, you are aware that placards are not required on a transport vehicle which contains less than 454 kg (1,001 lbs) aggregate gross weight of hazardous materials covered by table 2 of paragraph (e) under § 172.504. In the scenario you describe, the pick-up truck and trailer are two separate transport vehicles each carrying less than 454 kg (1,001 lbs) of eligible hazardous materials. Therefore, neither the pick-up truck nor the trailer is required to be placarded in highway transportation.

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


Hattie L. Mitchell

Chief, Regulatory Review and Reinvention

Office of Hazardous Materials Standards

171.8, 172.504

Regulation Sections

Section Subject
171.8 Definitions and abbreviations
172.504 General placarding requirements