Interpretation Response #13-0005 ([ATDynamics, Inc.] [Mr. Jeff Grossmann])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: ATDynamics, Inc.
Individual Name: Mr. Jeff Grossmann
Location State: CA Country: US
View the Interpretation Document
Response text:
February 21, 2013
Mr. Jeff Grossmann
Vice President Engineering
ATDynamics, Inc.
3150 Corporate Place
Hayward, CA 94545
Reference No.: 13-0005
Dear Mr. Grossmann:
This is in response to your December 31, 2012 email, and follow up conversations with a member of my staff, requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). You provide a picture of a highway trailer with "boat tail" extensions installed. You ask for confirmation that the placard placement shown in the pictures and diagrams is compliant with § 172.516. You also ask if there are additional mounting locations that could be deemed suitable.
Placards are required to be clearly visible from the direction they face by § 172.516(a). From the pictures you have submitted it appears your placard placement meets this requirement. Placards are also required by 172.516(b)(2) to be located clear of appurtenances and devices such as ladders, pipes, doors, and tarpaulins. While the placement of the placards shown are clear of such appurtenances and devices; extra care may need to be taken during placard application to ensure placards are not obscured by appurtenances such as door handles or the "boat tail" itself.
Due to variations in truck design and appurtenance locations it is impossible to validate most options as suitable for all trucks. Any location that satisfies the conditions of § 172.516 is suitable for placard placement.
I trust this satisfies your inquiry. Please contact us if we can be of further assistance.
Sincerely,
Delmer Billings
Senior Regulatory Advisor
Standards and Rulemaking Division
172.516
Regulation Sections
| Section | Subject |
|---|---|
| 172.516 | Visibility and display of placards |