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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 #10-0254 ([Department of California Highway Patrol] [Captain Steve Dowling])

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

Interpretation Response Details

Response Publish Date:

Company Name: Department of California Highway Patrol

Individual Name: Captain Steve Dowling

Location State: CA Country: US

View the Interpretation Document

Response text:

March 16, 2011

 

 

Captain Steve Dowling

Department of California Highway Patrol

P.O. Box 942898

Sacramento, California 94298-0001

Ref. No. 10-0254

Dear Mr. Dowling:

This responds to your November 10, 2010 letter requesting further clarification of placarding requirements in § 172.516 of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You disagree with our response to Mr. Wes Pace in letter Ref. No. 10-0075 (attached) regarding placarding shrinkwrapped pallets of non-bulk packages on a flatbed transport vehicle and request further clarification.

In our response to Mr. Pace, we indicated that required placards may be attached or affixed to the load of packages instead of the flatbed transport vehicle itself. We also indicated that the shipment must conform with the display and visibility requirements in the HMR. In your letter, you agree with the placement of placards on an overpack of non-bulk packages is not prohibited as long as the visibility requirements are met. However, you do not agree with our opinion that required placards may be attached or affixed to the overpack instead of the flatbed transport vehicle itself.

It is the opinion of this office that the PHMSA letter in question (Ref. No. 10-0075) is a valid response. In the situation described in letter Ref. No. 10-0075, the general placarding requirement in § 172.504(a) stating that each transport vehicle containing a placardable quantity of hazardous material must be placarded on each side and end may be met by placarding a pallet of non-bulk packages on a flatbed transport vehicle. In accordance with

§ 172.516, the placards must be clearly visible from the sides and ends of the transport vehicle.

I hope this answers your inquiry. If you need further assistance, please contact this office on 202-366-8553.

Sincerely,

Charles E. Betts

Director

Standards and Rulemaking Division

172.516, 172.504

Regulation Sections

Section Subject
172.504 General placarding requirements
172.516 Visibility and display of placards