Interpretation Response #10-0126 ([Minnesota Department of Transportation] [Mr. Michael Ritchie])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Minnesota Department of Transportation
Individual Name: Mr. Michael Ritchie
Location State: MN Country: US
View the Interpretation Document
Response text:
October 26, 2010
Mr. Michael Ritchie
Hazardous Materials Specialist
Minnesota Department of Transportation
Commercial Vehicle Operations Section
395 John Ireland Boulevard
St. Paul, MN 55155
Ref. No.: 10-0126
Dear Mr. Ritchie:
This responds to your letter regarding placarding and marking of cargo tank motor vehicles in accordance with the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You asked whether the required placards and markings, including the proper shipping name or common name and the INHALATION HAZARD marking, must be displayed directly on the cargo tank, or may the markings and placards be displayed on the "vehicle equipment boxes" or other appurtenances, as shown in the enclosed photographs of cargo tank motor vehicles in Liquefied Petroleum Gas (LPG) and Anhydrous Ammonia service, as long as the placards and markings are clearly visible.
A cargo tank meets the definition of a bulk packaging and must be placarded on each side and each end. Section 172.516 states that each placard on a motor vehicle must be readily visible from the direction it faces except from the direction of another transport vehicle to which the motor vehicle is coupled. Generally, placards on the sides and ends of the cargo-carrying portion of a vehicle"s cargo body satisfy requirements for placarding the sides and ends, as long as they are readily visible and not obscured by appurtenances in the direction they face.
It is the opinion of this Office that a cargo tank motor vehicle placarded and marked with an identification number display, including the proper shipping name or common name and the INHALATION HAZARD marking, as depicted in your photographs, complies with the requirements in §172.516 for visibility and display.
I hope this information is helpful. If we can be of further assistance, please contact us.
Sincerely,
Ben Supko
Acting Chief, Standards Development
Office of Hazardous Materials Standards
172.516
Regulation Sections
| Section | Subject |
|---|---|
| 172.516 | Visibility and display of placards |