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Interpretation Response #16-0166 ([Halliburton] [Mr. Albert Vandeaver])

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

Interpretation Response Details

Response Publish Date:

Company Name: Halliburton

Individual Name: Mr. Albert Vandeaver

Location State: TX Country: US

View the Interpretation Document

Response text:

January 12, 2017

Mr. Albert R. Vandeaver
Haliburton HRD
4375 S. Loop 1604 E.
Elmendorf, TX  78114

Reference No. 16-0166

Dear Mr. Vandeaver:

This letter is in response to your October 12, 2016, letter requesting clarification of the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180) applicable to placarding.  You describe in your letter a scenario where a pickup truck with a trailer attached contains an amount of hazardous materials that requires placarding.  Specifically, you ask whether the front of the pickup truck may be placarded to satisfy the front placard requirement prescribed in § 172.504(a).  

The answer is yes.  Except as otherwise provided by the HMR, each bulk packaging must be placarded on each side and each end with the type of placards specified in Tables 1 and 2 of
§ 172.504(e).  However, as authorized in § 172.516(b), the required placarding of the front of a motor vehicle may be on the front of a truck-tractor instead of or in addition to the placarding on the front of the cargo body to which a truck-tractor is attached.  Therefore, the placarding scenario you describe in your letter is authorized by the HMR.  

I hope this information is helpful.  Please contact us if we can be of further assistance.


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

172.504(a), 172.504(e), 172.516(b)

Regulation Sections

Section Subject
172.504 General placarding requirements
172.504 General placarding requirements
172.516 Visibility and display of placards