Interpretation Response #15-0224
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
January 13, 2016
Ms. Shannon Schick
Bulk Hazardous Materials Manager
Schneider National Bulk Carriers
1555 Glory Road
Green Bay, WI 54304
Ref. No.: 15-0224
Dear Ms. Schick
This responds to your letter dated November 17, 2015, requesting clarification on whether affixing placards to a motor vehicle with tape satisfies the requirements of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180). In your letter you enclose a picture and describe a method of affixing placards by placing duct tape along the outer borders of a placard in which the tape covers only the border of the placard and does not obscure any part of the surface other than the borders.
The method described in your email and the picture is an acceptable method of affixing a placard provided the placard is securely attached or affixed (see § 172.516(c)(1)). Also, the HMR require a placard to be affixed to a background of contrasting color or have a dotted or solid line outer border which contrasts with the background color (see § 172.516(c)(7)). The dotted line border is not part of the placard specification. However, a dotted or solid line outer border may be used when needed to indicate the full size of a placard that is part of a larger format or is on a background of a non-contrasting color (see 172.519(b)(2)).
I hope this answers your inquiry. If you need additional assistance, please contact the Standards and Rulemaking Division at (202) 366-8553.
Duane A. Pfund
International Standards Coordinator
Standards and Rulemaking Division
172.516(c)(1), 172.516(c)(7), 172.519(b)(2)
|§ 172.519||General specifications for placards|