Interpretation Response #15-0076 ([The Lane Construction Corporation] [Ms. Michele Jacobs])

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

Interpretation Response Details

Response Publish Date: 07/09/2015

Company Name: The Lane Construction Corporation

Individual Name: Ms. Michele Jacobs

Location State: CT Country: US

View the Interpretation Document

Response text:

July 9, 2015

Ms. Michele A. Jacobs
The Lane Construction Corporation
90 Fieldstone Court
Chershire, CT 06410

Ref. No. 15-0076

Dear Mr. Jacobs:

This is in response to your April 17, 2015 letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to placards. You ask what kind of damage would have to occur to a placard for it not to meet the placard specification in § 172.516. In your letter, you include a picture of a placard with a rivet hole and ask if it would be acceptable under § 172.516.

The answer is yes. It is the opinion of this Office that the placard depicted in your letter would be acceptable under § 172.516. As required by § 172.516(c)(6), each placard on a transport vehicle, bulk packaging, freight container or aircraft unit load device must be maintained by the carrier in a condition so that the format, legibility, color, and visibility of the placard will not be substantially reduced due to damage, deterioration, or obscurement by dirt or other matter. The Pipeline and Hazardous Materials Safety Administration (PHMSA) cannot make a broad determination about what would be considered substantial damage to a placard. Therefore, PHMSA must consider whether the condition of a placard is still acceptable on a case-by-case basis.

I hope this satisfies your request.

Sincerely,

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

172.516, 172.516(c)(6)

Regulation Sections