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Interpretation Response #12-0246 ([AWP, Inc.] [Mr. Eric A. Hulme])

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

Interpretation Response Details

Response Publish Date:

Company Name: AWP, Inc.

Individual Name: Mr. Eric A. Hulme

Location State: OH Country: US

View the Interpretation Document

Response text:

January 22, 2013

Mr. Eric A. Hulme
Director of Compliance & Training
AWP, Inc.
826 Overholt Rd.
Kent, OH 44240

Ref. No. 12-0246

Dear Mr. Hulme:

This is in response to your October 23, 2012 e-mail requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to prohibited and permissive placarding.  Specifically, you ask whether the logos as shown in the illustrations you supplied are prohibited under the HMR.

The answer is yes.  As provided in § 172.502(a), no person may affix or display on a packaging, freight container, unit load device, motor vehicle or rail car any sign, advertisement, slogan, or device that, by its color, design, shape or content, could be confused with any placard prescribed by the HMR.  This prohibition is intended to limit the potential dilution of hazard warning communication provided by the appropriate hazardous materials placards.  The illustrations you provide depict the same shape (i.e., square-on-point configuration), size (i.e., 10 inches by 10 inches), and color (i.e., orange with black legend) as that of hazard warning placards.  These logos, in the aggregate, can be confused with a Class 1 (explosive) placard prescribed in the HMR and are therefore prohibited under § 172.502.

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


T. Glenn Foster
Chief, Regulatory Review and Reinvention Branch
Standards and Rulemaking Division


Regulation Sections

Section Subject
172.502 Prohibited and permissive placarding