Interpretation Response #12-0184 ([Ms. Shari Ann Fry])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name:
Individual Name: Ms. Shari Ann Fry
Location State: OK Country: US
View the Interpretation Document
Response text:
October 3, 2012
Ms. Shari Ann Fry
6107 East 186th Street South
Bixby, OK 74008
Ref. No. 12-0184
Dear Ms. Fry:
This responds to your August 16, 2012 letter requesting clarification of the placarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). In your incoming letter you note that state enforcement personnel are issuing violations to truck drivers for not placing the required placards on their trucks at least 3 inches away from other required placards. These enforcement personnel are citing § 172.516 as the reason for these violations noting that it is their opinion that placards are considered another marking under § 172.516. Specifically, you ask if placards are required to be placed at least 3 inches from other placards.
The answer is no. In accordance with § 172.516(c)(4) placards must be located away from any marking (such as advertising) that could substantially reduce its effectiveness, and in any case at least 3 inches (76.0 mm) away from such markings. A placard is not considered a marking in this case. The intention of § 172.516(c)(4) is to limit the potential dilution of hazard communications by other markings not required by the HMR. There is no specific requirement to have placards at least 3 inches from other placards.
I hope this answers your inquiry. If you need additional assistance, contact this office at (202) 366-8553.
Sincerely,
Robert Benedict
Chief, Standards Development Branch
Standards and Rulemaking Division
172.516
Regulation Sections
| Section | Subject |
|---|---|
| 172.516 | Visibility and display of placards |